How Best Buy Refreshed Its Code of Ethics
by Bill Coffin
Reading the Best Buy Code of Ethics is almost like entering a Best Buy store itself—everything is bright, neatly arranged, and inviting. Best Buy takes its Code seriously as part of a program that has earned World’s Most Ethical Companies honors 10 times so far.
This article will showcase how Bill Underwood, Best Buy’s Senior Director, Global Compliance and Ethics, keeps the Best Buy Code fresh and up to date while upholding high standards for design and readability, advocating for a creative vision, and aligning the finished product with Best Buy’s strategic needs.
A Mission Critical Process
Best Buy creates its Code by utilizing a third-party vendor, which Bill works with closely. The process of the Code update begins with a due diligence process that involved reviewing as many peer codes as possible. By seeing how different companies present their various Codes, Bill could tell what he felt would work for Best Buy, and what wouldn’t. Bill also made this part of his vendor Request for Proposal process, so he would ensure that the vendor Best Buy hired would understand Bill’s vision for the project. While he did that, he also connected with subject matter experts from across the company that he knew he would need to rely upon while writing the Code. All of this revolved around two intersecting objectives: to create a document with a clean design and generous white space for easy reading, and to express the Code’s content in a single voice that unifies procedures and processes from across the enterprise.
“Avoiding legalese was a critical part of what makes it successful,” Bill says of the current Code. “We often refer to our Code as our North Star. And anytime there is any significant new brand work, the code really should follow that brand.”
A recent brand refresh meant the Code needed refreshing, too. It was exciting to take the companywide energy generated by the new brand guidelines and express them in the Code of Ethics, but this also meant that a lot of stakeholders were interested in the project beyond the Legal and Compliance teams. Best Buy’s Marketing and Creative teams were also invested in seeing how the new document would take shape because it was the first real example of the new brand guidelines in action.
How to Advocate for a Creative Vision
Creating a single voice for the Code is an extremely difficult task, Bill said, because it means getting all of the SMEs on the project to agree to a single way of expressing things. In the beginning, he spent a fair amount of time getting to know the subject matter experts that would be involved on all of the respective topics within this document. “I met with every single one of them individually to convey to them that one of the central goals of this project was to have one voice, that it wasn’t just a combination of 40 different voices from across the company,” Bill says. This helped get through the Code’s first draft, when different writing styles and standards provided for ample opportunities to disagree. Even on matters such as the infamous Oxford comma, Bill asked his colleagues to put aside their personal preferences for the sake of the document and instead, to focus on whether the content in their respective sections aligned with company policy and reflected the current legal landscape.
“That allowed us to have a document that really speaks to all 85,000 of us across the enterprise,” Bill says. But it has never been easy work. The original version of the Code he developed in 2018 took around 15 months to complete, from ideation to finished product.
Perhaps the biggest compliment Bill has received on the Code thus far has come from peers who told him that they read it, they enjoyed it, it taught them something, and most of all, it guided them in specific instances.
“I know how that sounds,” Bill says. “But this isn’t a document that people often spend time with.” He thinks the reason why people actually read the Best Buy code—and why fellow ethics and compliance colleagues use it as an example to follow themselves—is because of the sheer amount of time and effort Bill and his team puts into how the document looks and reads. “That’s why I continue to be a stickler every year with annual edits,” Bill says. “Those sorts of compliments encourage me to stay on the path or protecting this Code’s sole voice.”
To review Best Buy’s Code of Ethics, visit the Best Buy ethics page.
For free examples of other best-in-class codes as well as helpful reports, presentations, webinars, and more, please visit the Ethisphere Resource Center.
To read about more Codes of Conduct that we love, click here.

