Compliance Communications Blog

Navigating The Office Politics Of A New Code Of Conduct


You’ve been receiving emails from staff members asking for clarification on basic principles in your current Code of Conduct. An alarming number of anonymous reports are being filed saying corporate compliance isn’t being followed. And far too many employees at your company are involved in risky practices without malicious intent.

As a compliance professional, you recognize the need for a newly written and released Code of Conduct. It’s necessary to have a clear philosophy on what the Code will be, but if this vision is not shared by others in your company, your Code writing project is unlikely to succeed.

Releasing a brand-new document of such importance is not a project that can be tackled unilaterally. At some companies, critical stakeholders are not bought-in on either the approach to the project or, in some cases, even the need for a new Code to be written. This kind of political resistance is never conducive to a smooth process.

Prevent this situation from happening at your company by understanding and planning for the politics involved in the rollout of your new Code.

Assembling A Team For The Code Review Process

To ensure that your newly written Code is met positively, it is essential to create a review team before the project begins. Identify all of the stakeholders who should be involved, such as legal subject-matter experts (e.g., Bribery and Corruption, Insider Trading), Human Resources, Internal Communication and someone who represents communication from the CEO. Also include representatives of line employees and your global workforce who can provide valuable insight into how to make the language of the Code as relevant as possible to all.

Plan for all of these individuals to meet so that the group gains an understanding of the Code project and agrees on both a philosophy and the list of topics to include. Specifically ask all of the subject-matter experts what they feel is most important to impart to the all-employee audience for the Code, as well as what is new or emerging in their area of expertise.

This large team may also do a first review of certain elements of the Code, but once that has been completed, a smaller group (e.g., Ethics and Compliance, Legal, HR) should commit to the subsequent reviews, resolution of conflicting input and completion of the final document. If you don’t step subsequent reviews down to a smaller core group, you may never complete the review process.

Planning For The Rollout Of Your New Code

Once the Code has gone through the smaller review team and been approved, roll it out to the entire company in a high-profile mode. Nothing is more important to Code adherence than making it well publicized and well understood.

Make the rollout big and exciting. The announcement could be anything from an email from the CEO to an enterprise-wide celebration of “Compliance Week” at your company, complete with brand-new corporate compliance materials. Your company’s culture should dictate the right channel to roll out the big news.

By involving necessary stakeholders at the ground floor of your new Code of Conduct, you are greatly reducing the risk of a necessary team member holding up the rollout out of spite. If everyone from the CEO to the Human Resources Manager feels that they were well informed and even consulted on the new Code, your rollout will be seen as the exciting result of teamwork and avoid any unwanted office politics.

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Navigating The Office Politics Of A New Code Of Conduct

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