5 Codes of Conduct We Love & Why
The Code of Conduct is the foundational document that broadly establishes the expectations for behavior and can be described as the “house rules” for an organization. It is the cornerstone of how the company chooses to do business and provides guidance on interactions with colleagues, customers, business partners, third parties, and other stakeholders.
The Code sets the tone for an organization’s culture and should be tailored to its specific risks, industry, geography, and history and be grounded in the mission and values of the organization. No one document can cover all the do’s and don’ts for every possible scenario, but an effective Code communicates principles for behavior and explains why employees should care.
What makes a good Code of Conduct?
1. Tone
The tone of the Code of Conduct should be aspirational and serve as a guide to employees for how they and others at the organization should behave. It should be consistent with the mission, purpose, and values of the company.
Make sure the Code includes:
- A clear statement of how the company chooses to do business
- Letter from leadership (CEO or Chief Compliance Officer) that sets an inclusive, inspirational tone and connects the Code with the company’s mission or purpose
- Explanations of why the reader should care about the topics in the Code
2. Content
Effective Codes emphasize the importance of asking questions and sharing concerns, as well as provide guidance on how to speak up and detail the company’s commitment to non-retaliation. This information can be first introduced in the letter from leadership and should be reinforced throughout the Code. Ideally, callouts for Speak-Up should be included in key locations throughout the Code.
All reporting channels should be listed predominately with direct links to websites, platforms, emails, or phone numbers as applicable. Consider also including the process or workflow of investigations to increase transparency for employees and show them how they will be protected from retaliation.
The Code should address the company’s position on key risk areas and provide guidance on the best course of action that aligns with the company’s values through the use of concrete examples and comprehension aids like decision trees, tips, or definitions of key terms.
Common risk areas addressed in Codes include (but are not limited to):
- Inclusion & Diversity
- Bullying
- Harassment & Discrimination/Equal Opportunity
- Health & Safety
- Conflicts of Interest
- Gifts & Entertainment
- Free & Fair Competition
- Preventing Financial Crimes
- Economic Sanctions
- Confidential Information
- Vendor/Third-Party Relationships
- Open & Honest Feedback
- Speak Up
- Social Media & Communications
- Recordkeeping
- Corporate Responsibility & Sustainability
- Human Rights
- Data Privacy & Information Security
- Protecting & Appropriate Use of Company Assets
- Workplace Violence
- Investigations
3. Accessibility
Increasingly, companies are sharing their Code of Conduct both internally (i.e., on a main intranet site, a Policy Hub, the Ethics & Compliance intranet page, etc.) and externally (i.e., on their public website). It should be easy to find and compatible with both desktop and mobile viewing. The Code should be available in the relevant languages for employees, third parties, prospective employees or customers, and others.
When determining if the Code is accessible, ask:
- Can it easily be found by people inside and outside of the company?
- Is it available in languages that our employees speak?
- Is it compatible with disability aids, such as text readers?
- Can it be read on a mobile device?
4. Design & Organization
Gone are the days of the dense, text-only Code of Conduct. Today’s Codes are a reflection of the company and should be aligned with brand identity, so it looks and feels like the company. Additionally, it should be organized logically, be easy to use and navigate, and support the reader’s experience and comprehension.
Design elements that make the Code more engaging and easier to read:
- Use of white space
- Varied font sizes and colors
- Inclusion of shapes and images
- Callout boxes with tips, helpful hints, or key definitions
- Graphics that help the reader understand a process or workflow
5 Examples of Best-In-Class Codes of Conduct
1. Lincoln Financial
Lincoln Financial’s Code of Conduct is a web-based, interactive Code that is easily accessible on and response to any device. It is organized around the company’s core values and leadership attributes for individuals, the company, and those they serve and do business with.
The top corner of every page includes buttons for a glossary of key terms to aid in the reader’s understanding and a list of helpful resources, what they can help with, and how to access them with links, email addresses, and phone numbers. The Code includes comprehension aids like callout boxes with clear guidance for employees, videos, decision-making models, and Q&A examples.
2. ManpowerGroup
ManpowerGroup has made their Code of Conduct available in 23 languages, appropriate for their global footprint and employee base, making it highly accessible for readers and employees. The Code also includes an excellent example of an executive introduction from their Chairman and CEO that is highly personalized to the company, including details about its history, mission, and industry, emphasizes Speak-Up, and shares the company’s commitment to ethics and integrity.
The Code also includes concrete examples, scenarios, and explanations for topics addressed in the Code, as well as important definitions, graphics, images, and knowledge checks.
3. Rockwell Automation
Rockwell Automation’s Code of Conduct has exemplary use of comprehension aids that help employees understand concepts and provide guidance on how they should act. These include callout boxes with definitions of key terms, bulleted lists that detail how employees should behave, and scenarios that illustrate an issue and give guidance on how employees should respond.
The Code also includes engaging design elements like varied font sizes and colors, images to break up large bodies of text, sidebars, and more. Additionally, there are links to company policies throughout the Code and navigation buttons on the bottom of each page to the table of contents and the page that lists contact points for speaking up.
4. U.S. Bank
U.S. Bank’s Code of Conduct emphasizes the importance of Speak-Up, including a dedicated page at the beginning of the Code that has links to multiple reporting options, a clear and intuitive layout describing the reporting process, and details of the company’s commitment to non-retaliation. The header of every page also includes a button for the Ethics Line, reinforcing the importance of speaking up and reporting concerns.
The Code also includes other types of comprehension aids throughout the document, such as an ethical decision-making model, Q&A examples, callout boxes, and links to related resources. Additionally, the Code is aligned with U.S. Bank’s branding, with colors, images, and phrases that visually connect the reader to the company.
5. Snap, Inc.
Snap, Inc.’s Code of Conduct is a great example of a Code that is very aligned with and reflective of the company’s brand identity. The main brand color, yellow, is used throughout for emphasis. The Code also uses a mix of images reflective of company places and people, as well as illustrated avatars like the ones available in their main product, Snapchat.
The Code is also values-based, organized as a “Guide to Kind Business,” and details how employees should be kind to each other, their community, their partners, their investors, and the world. The emphasis on kindness is further reinforced in the callout boxes that give practical guidance as they are all headed with “How We Are Kind.”
BELA Members have access to Ethisphere’s library of sample codes, policies, and resources across ethics and compliance programmatic elements. Request guest access to the BELA Member Hub to check out the library today.
