Following a “Code of Conduct” is a concept that should seem familiar. From an early age it is likely that you have been presented with various “codes”, some more enforced than others, and had to sort out their significance to your actual conduct.

Famous Codes:

All three of these documents share some things in common – clear language, some bright line rules (“Customers’ orders must be serviced promptly and accurately”, “I will accept neither parole nor special favors from the enemy”, “GE absolutely prohibits retaliation”), and an attempt to link the “Code” to a higher purpose(s) than simply rule following.

And there is much to be said for getting it all on one page or two.

Any Code will have several audiences with varying levels of education. The challenge is to appeal AND be clear to all.


Notably, there is no requirement in the federal Sentencing Guidelines that a company adopt a “Code”, although the guidelines do require adoption of “standards and procedures to detect and prevent criminal conduct.”(Section 8B2.1(b)(1)) The few, scattered government requirements relating to Codes are linked on the “Mandatory Programs” page. But aside from these, the adoption and implementation of a Code of Conduct for the organization will generally be an act of virtue - not compliance.

Where is the Code?

Aside from the tone and language in which it’s written, the availability of the company’s “Code” speaks volumes about how seriously it is regarded by the company and those who work there. For many companies these days their internet site(s) are an important part of their “brand” and the principal route by which they accept employment applications. Is the “Code” on the home page of the website? Or one click away as with this government contractor, and this large hospital corporation? Is there a review – or even a reference to – the company’s Code when applying to work there? Is the code linked to a page marked “investors” or some place that a member of the general public might see it?

Even a great code is less effective if you have know it’s there to find and read it.

Codes +

The recent trend in Codes is to publish them with embedded hyperlinks to additional resources, like this one from Kimberly Clark, this one from Yahoo, and this one from Tyco. Others include interactive questions for the reader to test and reinforce comprehension, as in this Code from Manpower. Digital publication capability lets a company, like Tullow Oil, make their Code word searchable, tweetable and linkable to the reader's Facebook account. RAI has included a topical listing of situations and solutions that might impact its Code. CISCO has chosen to make its Code available as an interactive e-book with embedded videos, hyperlinks, and policies. This Accounting organization uses interactive "Dilemmas" to reinforce its Code. The University of Alabama at Birmingham has developed hypothetical examples to illustrate how its Code works in practice.

If your operations involve those with differing languages or geographically distant, digital publication makes it easy to distribute versions in different languages and also to do your Code "training" online.

The "Code Video" is also a growing phenomenon as these examples, done on varying budgets, illustrate:

"I Agree"

In addition to writing and distributing a Code, most organizations has developed a method of obtaining at least an initial, sometimes annual , executed commitment from individuals to the contents of the Code. These may be called "Attestations", "Certifications" , "Acknowledgements". The same form may be executed by all or some organizations have special ones for leaders. The contents of this document can also vary quite a bit from a simple phrase like " I have received, read and understand.." to multipage documents including hyper-linked resources.

The language of these documents can also vary substantially. There are those clearly written by lawyers (does anyone else use the phrase "I hereby acknowledge"?) to somewhat straightforward descriptions of expected actions ("I will report"), "I am responsible for ") "I" statements are the norm, although not necessarily a best practice.

All but the smallest organizations face a challenge obtaining and maintaining these commitment forms. Not surprisingly the company's website often plays a role whether it is (a) the place from which to download, print and sign a copy that gets sent to - the Compliance Office/ Human Resources / your supervisor; (b) the location for obtaining a copy of the Code and attesting online or (c) a place for simply submitting an electronic "signature". One company used the popular tool Survey Monkey to distribute its Code and collect "personal commitments" This company has an online "Affirmation" process.

The leadership role - this University annually collects not only individual Attestations but also "Confirmations of Receipt" from each department head that are then forwarded to the Compliance Office. One multinational corporation uses a "certify up" process for its 5,700 leaders, including the CEO.

Code Collections:

  • Over 1,000 Codes of Ethics in one place - the Illinois Institute of Technology's, Center for the Study of Ethics in the Professions maintains an online Collection

  • Bell: the Business Ethics Links Library has a searchable database of company ethics codes (University of Colorado, Boulder)

More Exemplar Codes:

Opinions About Codes

this one from Tyco