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Is Your Code of Conduct Worth the Paper It’s Written On

Given that there seems to be little or no correlation between the existence of a code of conduct and ethical behavior in the workplace, some compliance professionals are, understandably, beginning to question if codes of conduct are still relevant or useful.

Codes of conduct have been a standard artifact of corporate compliance programs for decades. The outstanding feature of many of them is the complete disconnect between organizations’ espoused values and their actual business practices.

We are responsible for conducting the business affairs of the companies in accordance with all applicable laws and in a moral and honest manner… We want to be proud… and to know that [our company] enjoys a reputation for fairness and honesty and that it is respected.

This quote comes from Enron’s code of conduct at the time of the corporate scandal that kick-started the exponential growth in compliance programs worldwide.  Sadly, in the intervening years, it seems that little has changed. This excerpt from Oxfam’s Code of Conduct at the time of the Haiti earthquake illustrates the point sharply:

The Code of Conduct is … written to reflect the organisations’s fundamental beliefs and values … to support its mission to work with others to overcome poverty and suffering and its commitment to ensuring that staff members avoid using possible unequal power relationships for their own benefit.

Abandon all hope? 
Codes of conduct are not necessarily doomed to failure.  However, to achieve impact and relevance we need to revisit our approach to writing, producing, and communicating them.  
For too many organizations, a code of conduct is still just a tick in the compliance program box.  The ‘lip service’ code is fairly easy to spot:

  • It’s long, wordy, and excessively legalistic in tone.
  • It’s bland in tone and visual design, reflecting little, if anything, of what makes the organization unique.
  • It’s hard to find, often buried in the depths of the corporate intranet along with other lengthy and largely ignored policy documents.
  • It’s rarely communicated widely or actively endorsed by senior business leadership and middle managers.  Nobody is really walking the talk.   

Keys to a successful code
If you think your code of conduct needs a revamp, take three key things into consideration:

  • The content you write
  • The process you follow
  • The tools you use to produce and communicate your code

Content is key
The success of your code is largely determined by how effective and persuasive the content is. Here are some tips for writing good content:

  • Be mindful of your audience: I see many codes of conduct that are little more than a long, disjointed list of risk areas that happen to be front of mind for compliance professionals at any given time.  Remember, you are writing to try to influence the behavior of employees and they simply do not experience risk in those same silos.  Write for your target audience and consider framing your code around your key stakeholders’ needs and concerns: the business processes they are involved in and the likely ethical dilemmas they will face.
  • Be authentic:  Readers of your code, particularly employees, understand your corporate culture and ‘how things are done around here’.  Your readers will not respond favorably to a document that does not feel authentic.  Even if your business has experienced compliance issues in the past, your code can signal a sea change and can be a valuable tool to set out your honest aspirations for the future.
  • Be practical: Readers will engage with your code if they sense value.  Rather than telling them about their legal obligations, help them understand how the law applies to them and where they can get help and advice if they need it.
  • Be emotional: Research shows the strong connection between emotion and decision making.  This is a well-understood concept in the worlds of marketing and behavioral economics and can arguably be harnessed to improve the effectiveness of codes of conduct.  If you want your code of conduct to influence ethical decision making then you should focus on the ‘why’ as well as the ‘what’ and the ‘how’ of compliance and ethics.

Perfect your process
The process of drafting, reviewing, and approving a code of conduct can be long and convoluted.  Through revisions and multiple stakeholder input, we often lose sight of the most important group: the readers.  

If you want to know if your code of conduct is going to have the desired impact then you need to market test it, just as you would with any new product.  Test both the content and the media you are planning to use with your target audience through focus groups and interviews with a representative sample of code users. Moreover, be prepared to take on board what you learn.

Also, think about the process you are going to use to distribute your code.  A well-orchestrated launch or re-launch campaign can be a great vehicle for refocusing your organization on ethical issues.  And, consider the power of the marketing inspired ‘call to action’ – that is, actually requiring readers to do something with the code.  This could be as simple as having employees certify that they have read and agree to abide by it.  Not only does this create a valuable audit trail but there is evidence to suggest that signing up to what can be perceived as an ‘honor code’ can cause people to behave more ethically.  (See Dan Ariely’s fascinating Ted Talk to learn more about his experiments in this area.)

The right tools for the job
While a print-on-paper document may look good on the coffee table in the lobby, there is a now a wealth of digital tools that can make your code of conduct more accessible, interactive, and of genuine value to employees.

Recent research suggests that almost half of all smartphone users spend more than five hours a day on their mobile devices, and also spend more time online on their phones than computers. Although a mobile phone may not be the delivery mechanism you’ve traditionally used in the past for a multi-page document like a Code of Conduct, it does offer some unique benefits. The technology itself creates new opportunities to engage your target audience with key messages and nudges to drive appropriate behaviors in the workplace, while also offering the flexibility to access and consume the information in your Code of Conduct more easily than if it were printed on paper or saved on their computer at work. 

Aside from your target audience, consider what tools you can provide to senior leaders and managers to equip them to become willing and active advocates of your code of conduct.  Middle managers are one of the most influential groups when it comes to impacting employee behavior.  Get them to believe in your code of conduct as a business enabler, and arm them with the knowledge and skills to pass that belief onto their teams.

Do you need to breathe new life into your code of conduct?
If you’d like to know how your code measures up against industry best practices and what you can do to improve it, SAI Global is offering a complimentary code review to the first ten readers to respond to this blog.  

The review will be completed by one of SAI’s Advisory Services team and will be based on the full code review and rewrite service, highlighting the strengths and weaknesses of your current code and making recommendations for improvement.  Contact SAI for some practical advice about how to breathe new life into your code of conduct.

SAI Global also offers a wide range of ethics & compliance e-learning courses, with many topics closely relating to code of conduct.


Chart House Ethics helps companies drive business performance through the application of practical compliance and ethics solutions based on experience gleaned from over two decades of working with the world’s leading companies. Connect with Paula on LinkedIn.