Silence: Many employees won’t have the time or the interest to read the Code of Conduct. This disinclination can be exacerbated by keeping the rollout quiet. Even those who want to read it won’t look for it if they don’t know it exists.

Fanfare: Ideally, a new Code is rolled out with some fanfare: Its importance is reinforced on the company intranet and in printed materials, and it is incorporated into and referred to often in subsequent training programs.

Hard to Find: Post the Code of Conduct on a bulletin board in a back hall. Store the other copies in a drawer somewhere. Let someone who wants to read it badly enough track down the person whose job it was to file it away. A Code of Conduct that is not readily accessible to all employees- when they need to refer to it- is virtually useless and poses no threat to the current corporate culture. Employees faced with questionable situations won’t seek guidance from a Code of Conduct that they have to request from another office… often in a different time zone. Burying the Code of Conduct on the company website three levels down with obscure links helps too. Busy employees in the business development office are unlikely to take 15 or 20 minutes out of their day to dig through the company website looking for a Code of Conduct that they think they recall hearing about during annual training a few months back.

Easy to Access: Make the Code easy to access; provide printed copies for employees and place a link to it on the intranet.

Legalese: First, make sure the Code is only available in English. Second- and this is the most important part- make sure it’s in the kind of English that only a lawyer would understand. If your Code of Conduct does not exist in Chinese or in Russian, your employees in those countries will behave as though it doesn’t exist at all. They will have gotten the message: the local workforce was not worth the expense of translation. Regardless of your efforts to provide translations of the Code, using dense and overly legalistic terminology is guaranteed to confuse and exhaust your employees.

PlainSpeak: Ideally, the Code will be written in a style appropriate for a general audience and it will be translated into all applicable local languages.

Vague Directions: Keep the Code vague. Lay on the grand statements of good intent, and then pair them up with dark hints of consequences. A Code of Conduct that is too detailed or overly legalistic will confuse your employees, but too little guidance also presents problems. If your Code consists of one page full of grand aspirations it will be of little help to the employees who should depend on it. Principles of honesty, integrity and sound business ethics are laudable, but they are subjective. For the earnest employees trying to get things right, such language is not very helpful. For more devious employees, intent on inappropriate activities, such exhortations can be ignored or manipulated easily.

Clear Instruction: An ideal Code will not only inspire people to uphold high standards, but also provide clear guidelines on what to do, what not to do and when and where to seek guidance. No Code will ever answer all questions. Codes of Conduct should provide contact information for resources that can answer employee questions about gray areas. The Code should be the beginning, not the end, of ethics and compliance discussions.

Bottoms Up: If everyone at the top ignores the Code, you can be sure everyone below them will too. If senior management never mentions the Code, everyone else will conclude that it isn’t worth mentioning.

Top Down: An effective Code sets the company’s ethics and compliance tone and includes strong buy-in from senior management. If you expect your employees to comply with a Code of Conduct, let them hear from the top why the Code is important to your company and what it should mean to them.

Hollow Threats: You may think it’s enough just to omit mention of enforcement altogether, but you can do better: make some vague references to dire consequences, and then do absolutely nothing when employees are called out.

Consequences: In order to be effective, a Code of Conduct needs to set forth how it will be enforced, and then the company needs to follow through and enforce it. Employees notice when nothing happens to those who commit violations, even when consequences have been clearly specified. They’ll assume the Code is for show, and they’ll be right.

Static: You’ve drafted your Code of Conduct, translated it, launched it, distributed it, publicized it, endorsed it, explained it and enforced it … Time to move on to other projects. Sure. But don’t miss one final chance to sabotage the whole enterprise. Resolve to do nothing further, and permit the Code to drift out of date and into irrelevance.

Evolving: Codes of Conduct should continue to evolve as your company does. New languages should be rolled out as you enter new markets. New marketing strategies may require extension of the Code to commercial third parties. New risks may arise and new regulations may apply. An effective Code is an evolving document that expands to meet the current compliance environment.