8 Tips For Your Code Of Conduct’s Content, Tone And Organization

Having a clear, concise and well-written Code of Conduct is absolutely necessary for your company’s adherence to it.  An exasperating, wordy Code may leave too much gray area for employees to follow it properly. In fact, a Code that’s poorly written, or written for the wrong audience, may result in your compliance communication being totally ignored, thereby wasting your efforts and leaving your company at risk.

The effectiveness of your Code of Conduct relies on it being crafted in a professional yet easy-to-read manner. While this may seem daunting, creating such a Code of Conduct is actually very simple to achieve when you follow a few “best practices.”

How To Ensure Your Code Is Effective

Almost more important than what topics are included in your Code of Conduct is the question of how that content is expressed, and what extra elements surround it. Some of the keys to effectively impacting the company’s culture through the Code include:

1. Use language in the Code that is more positive in tone and less prohibitive, whenever it’s possible to do so. Examples of prohibitive tone to stay away from are:
   • “Employees may not …”
   • “No associate may …”
   • “You are prohibited from …”

   Better phrasing might include, “each of us must,” “our company depends upon,” and, “we must ensure.” This small change in tone makes a huge difference in how your Code will be interpreted. What you are trying to achieve is a team mentality. Your employees are more likely to participate in the shared vision of an ethical culture if they feel like they are all working together toward a common goal than if they feel like the Code is a set of rules they must obey.

2. Include a letter from the CEO at the front of the Code. Make sure it communicates the CEO’s vision of the ethical culture of the company, as well as the CEO’s own commitment to compliance and ethics. In many successful letters, the CEO offers a personal anecdote about a situation in which maintaining the greatest integrity was a hard yet ultimately successful choice.

3. Set up a Table of Contents in plain language to help employees and supervisors find the information that relates to their question or concern. This will be also be helpful for compliance training or when an employee needs a refresher on a corresponding situation that arises.

4. Include references to relevant company policies where they are mentioned in the Code or at the end of each chapter. Embed direct links to the policies in any electronic version for internal use, but not for the public version.  

5. Feature your company’s statement of values or principles in the beginning and then weave the values throughout the Code. It is important to reinforce that the Code is built upon the company’s values. You might also create a watermark with the value words in it and incorporate that into the design to further support this strong link between the values and the Code.

6. Include an easily referenced FAQ section. These questions put the application of the policy and behavior into a true-to-life context, which helps employees apply the information to their jobs. Offering these real-life examples in the Code helps make it as engaging a document as possible, as well as play its full role along the path to developing an ethical culture.

7. Prominently list resources for both advice and reporting. Be sure to include clear language describing the company’s non-retaliation policy surrounding the section of how to report any violations. This is required by exchange listing requirements for some companies and, of course, by the Sentencing Guidelines. In fact, the more this concept can be woven throughout your entire compliance program, the better.

8. Design and format the Code document for maximum readability. Remember, the main goal of your Code is to be easily understood by your employees. Eliminate long, dense paragraphs and move toward bulleted lists in the text. Also, break up blocks of text with white space and call-outs that help the eye more easily find sought-after content on the page.  

Drafting a Code of Conduct that can communicate with hundreds or thousands of people in an effective manner may seem nearly impossible, but it certainly doesn’t have to be. The use of different devices for communication within the Code, such as graphical images, keyword headers and subsections, will enable people of all learning styles to find and understand the information.

Ready to engage and empower your employees with a dynamic compliance communication plan? Download our free report, “5 Ways To Increase The Effectiveness Of Your Compliance Communications.”