Customizing Codes of Conduct to Spread the Message of Compliance

A carefully-drafted code of conduct should be a written manifestation of a company’s compliant tone and the bedrock upon which the company can build an effective set of anti-corruption policies and procedures.  The code should serve as a mission statement, emphasizing the company’s commitment to compliance and ethics, advised Eric Morehead, CCEP, Senior Compliance Counsel with NYSE Governance Services, who spoke at a recent program offered by the Society of Corporate Compliance and Ethics.  It should also provide employees and others with a roadmap for identifying and reporting issues and outline the company’s commitment to responding to problems, he said.  During his presentation, Morehead discussed actions a company should take prior to updating its code, suggested issues companies should consider when drafting a code from scratch and provided insight into recent relevant benchmarking surveys.  See also “Six Steps to Revitalize the Company Compliance Code” (Aug. 20, 2014).

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