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 SDOJ updates to the Evaluation of Corporate Compliance Programs (September 2024)

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5 Examples of Best-In-Class Codes of Conduct 

1. Lincoln Financial 

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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 

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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 

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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 

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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. 

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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.  

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