When to Update Your Company Code of Conduct

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Codes of conduct are, by their very nature, quite different. An effective employee code of conduct (note, I didn’t say a "good" Code) meets the needs of the organization – its geographic footprint, industry, risks appropriate to that industry, employee demographics, and organizational culture, history and mission.

A code of conduct clearly points out expected behaviors and demonstrates to employees as well as external stakeholders of all types an organization’s commitment to integrity.  An effective employee code of conduct not only communicates these behaviors but serves as a resource, a go-to place when questions about behavior arise.

Yet, in summary data from focus groups facilitated by NAVEX Global’s Advisory Services team, while more than 90% of employees report receiving the code of conduct and almost 100% will eventually certify that they’ve read it, when specifically, personally asked “Have You Read Your Code…Really Read It?”, the startling percentage drops down to 40-50%.  This disparity should be something that causes lack of sleep for compliance and ethics professionals as it speaks to the need for code of conduct review and revitalization.

In the recent NAVEX Global webinar, Ed Petry, Vice President with the Advisory Services team, stated that the most common Code mistakes are due to companies not keeping up with the changing risk profile of their organizations. If a code of conduct doesn’t mention behaviors that concern employees, e.g. concerns about social media, human rights, social responsibility, privacy and bribery, employees will not pay too much attention. And if the related behaviors are unenforceable or unachievable (e.g. ‘don’t use company assets for any personal matters’), employees will tune out.

But there’s more. If codes are too legalistic and wordy, if some topics are overdone, if a written or online version of the code is dull without graphics or interactivity, users won’t be drawn in and won’t truly comprehend what is – arguably – the foundation of your compliance and ethics program. And if you’re a global company and use US-centric images or language, you are legitimately at fault for not vetting a code with internationally-based colleagues.

If a code is structured or presented in a way that doesn’t properly present both values and risks, and uses so many different writing styles that your audience has trouble following along, you’ll lose attention and, worse, interest. And if your employees are comfortable with technology and have regular access to the internet, an online, interactive Code might be what they’re secretly hoping for instead of a 20-page expensive print document.

There’s a lot at stake. Your code is much more than a single policy. It is the overarching communication tool that summarizes your key policies at a high level and also serves as a resource for employees that tells them what they need to do. When was the last time you assessed or trained against your Code of Conduct? Is it in line with your values and updated to reflect societal changes? Consider updating your Code when it’s no longer in sync with your organization. It’s that simple.


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