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Memo to Managers
Making the Most of Our Code of Conduct
As you know, the company has a number of ethics and compliance resources in place to ensure that everyone understands our expectations and standards. These resources include training modules, our hotline and our Code of Conduct.
The code of ethics may be the most underutilized resource that we have. It is an excellent summary of our ethics and compliance standards, and it includes information about what we need to do to report problems and ask questions. And yet, for the most part, employees only refer to the code once a year during the annual certification process.
Everyone is busy, but if we aren’t proactive about ethics it can fall between the cracks. As a manager, you have a critical role to play in ensuring that employees and our business partners are clear on what they need to know and do when it comes to ethics and compliance. The more we discuss ethics and compliance, the more we make it clear that it is a priority for us, and that can go a long way to protect our company’s reputation and good name.
With this in mind, here are some tips for how you can make the most of our code to help deliver important messages about our commitment to ethics.
- Leave a copy of the code in a prominent, visible place in your own work area. This is easy to do and can be a good first step to raising awareness about the code. Also, arrange to have printed copies of the code available in common areas and restock when necessary. Though many of our resources are online, don’t underestimate the value of physical printed copies.
- Whenever you can, in team meetings and discussions with employees, refer to the code of ethics - especially to specific content. The more you’re seen using it, the more others will understand that it is a tool for them to use as well.
- Employees know that you understand their working conditions and the problems they face. They’ll trust you to help them apply our code and policies and focus on what’s important to them. Be selective. Draw their attention to topics in the code that apply to their work.
- When an employee comes to you with a concern, use the code. The code can help focus the discussion by helping to identify the specific concern and possible next steps. With the help of the code, you may be able to help turn a general question about fairness to a more specific and actionable concern. For instance, it may be that what the employee really has in mind is time charging: “I am concerned that others aren’t being held accountable and if we record time in this way, it won’t be in accordance with company policy.” Once the specific concern is identified, if necessary use the code to determine how best to escalate the issue as needed.
- Remember: our code of ethics is not just a resource for employees; it also is intended for our business partners and even the public. We want others to know about our commitment to ethics and compliance. Refer to the code and our standards when meeting with contractors and suppliers. If you meet with prospective employees or do public presentations representing the company explore how you might be able to leverage the code in your presentations.
And finally, we are continually gathering information about how to improve all of our ethics and compliance resources, including our code. We count on you to provide us with suggestions for how the code can be improved. What comments, praises or concerns are you hearing? Are there topics or risk areas that should be included or expanded in the next revision of the code? Have you seen other companies’ codes that you feel are more effective or user-friendly than ours?
Questions of the Month
Q: Who does our code apply to? Does it apply to all levels of employees? Does it apply to contractors and other third parties?
A: Our code applies to all levels of employees including officers. It also applies to our board members. Certain business partners, such as agents, consultants, vendors and temporary employees, serve as an extension of the company. They are expected to follow the spirit of the code, as well as any applicable contractual provisions, when working on our behalf. Managers who supervise our business partners and third parties have responsibilities to ensure that they understand our ethics standards. If an external business partner fails to comply with our ethics and compliance expectations and their related contractual obligations, it may result in the termination of their contract.
Q: What is the relationship between our code and our policies?
A: The code is designed to provide a high-level summary of our standards and expectations, to serve as a resource when you need information about our policies or when you (or others) are faced with a difficult ethical situation. The code does not replace our policies. It’s impossible to anticipate every question you may have or situation you might face, so in addition to the code, we also have other resources that can be of help. These additional resources are listed throughout the code. As always, the company relies on you to use good judgment and to seek help when you need it.
Imagine if you had the opportunity to reach out to every one of your employees, business partners and regulators to explain in a clear and concise way about your organization’s values and commitment to integrity. What if this was also an opportunity to let leadership set the ethical tone at the top, and to make it clear to employees and other stakeholders how to ask questions or report problems within your organizations?
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Using Compliance Communicator
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