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,” The FCPA Report, Vol. 3, No. 17 (Aug. 20, 2014).

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