Day 11 of 30 Days to a Better Compliance Program

You should employ a 6-step process to revising your Code of Conduct.

1. Get buy-in from decision makers at the highest level of the company

Your company’s highest level must give the mandate for a revision to a Code of Conduct. It should be the Chief Executive Officer (CEO), General Counsel (GC) or Chief Compliance Officer (CCO), or better yet all three to mandate this effort.

2. Establish a core revision committee

You should create a cross-functional working group should head up your effort to revise your Code of Conduct. It can include representatives from the following departments: legal, compliance, communications, HR; there should also be other functions which represent the company’s domestic and international business units; finally, there should be functions within the company represented such as finance and accounting, IT, marketing and sales.

3. Conduct a thorough technology assessment

The foundation of the revision process is how your company captures, collaborates and preserves the decisions during the revision. Use should utilize the technology available to you to do so. This is also important in your distribution plan, particularly if the Code will only be available in hard copy.

4. Determine translations and localizations

The DOJ and SEC require a local language component. You need to use  translations experts and know what they are doing when it comes to translations. Everyone must have the same understanding of the company’s Code-no matter the language.

5. Develop a plan to communicate the Code of Conduct

You should use the full panoply of tools available to it to publicize your new or revised Code of Conduct at roll-out. This can include a multi-media approach or physically handing out a copy to all employees at a designated time. You might consider having a company-wide Code of Conduct meeting where the new or revised Code is rolled out across the company all in one day. Also remember, you must document that each employee receives it.

6. Stay on Target

If you set realistic expectations you should be able to stay on deadline and stay within your budget. Do not be distracted by other issues that might arise during the process.

Key Takeaways

1. When did you last revise your Code of Conduct?
2. You must have senior management buy-in to successfully revise your Code of Conduct.
3. Keep your eye on the ball.

For more information, check out my book Doing Compliance: Design, Create and Implement an Effective Anti-Corruption Compliance Program, which is available by clicking here.