Code of Conduct: Criteria
At i2a, we have developed a set of 10 criteria to evaluate company code of conducts across a number of different sectors. We have also formed recommendations for writing a code.
There criteria have been formed with two key guiding principles: firstly, that the criteria should be measurable and secondly, that they were relevant in assessing the 'quality' of the Code.
They are as follows:
1. Ease of Access
Making the code readily available to those external to the company is a public demonstration of an organisational culture where the code is viewed as a core corporate document. Conversely, not making the document available may raise questions as to why an organisation would choose to keep the document internal.
For these reasons our first criteria considers how easy the code is to obtain in the public domain. We presumed that most companies make their code available internally, even when they do not publish it externally.
2. Presentation
In addition to making it readily accessible, having a document that is easy to read is important when trying to engage a diverse and often widespread audience.
In making the code a practical document, companies need to balance the volume of information and the way in which it is conveyed. Sometimes the code can take a contractual form - which can often result in it being filed away with an employment contract and not referred to again. Also, by ensuring the format is in line with other corporate policies and documents, companies can draw links between relevant documents more easily.
We have therefore looked at the branding of the document, the use of space and the overall impact which the presentation could have on the effectiveness of the document.
3. Structure
The code should contain information that is relevant to everyday situations that an employee may face. Ensuring that this information is organised in a logical, accessible format is crucial to ensuring usability. There are two main ways in which codes are usually structured - either by topic or by stakeholder group. In our experience we have found both structures have their advantages. However, to make either work well, a good content page and index is a must.
4. Language
It is increasingly important in global organisations where many languages are used throughout the company that the code is clearly written so that everyone is able to read and understand it easily. If it is necessary to use technical language, it should always be explained. Experience has shown us that although experts must be involved in developing the content they are often not the best people to actually write the code. Their familiarly with technical elements can make it challenging for them to make it appropriate for all readers.
5. Link to Purpose & Values
A differentiator between companies' codes is the extent to which the document is linked to the purpose and values of the organisation. Each organisation will have its own set of values and own mission statement. Clearly linking the contents of the code to the purpose and values of the company creates a convincing, tailored code to which employees can relate.
If companies adopt off-the-shelf codes or do not create a tailored document, the impression created is that management place little importance on the code as they have not invested the time to develop it into a central corporate document.
6. Provides guidance as well as rules
It is not possible to cover all situations that can arise in a working environment within a single document and this is recognised in a good code. It should, however, provide sufficient guidance to employees as to how to approach day to day situations and/or who they can go to for help and support. It is also important that there is sufficient emphasis on using moral judgement rather than looking for ways around rules.
There are many grey areas which can arise, for example, in the area of gifts and entertainment, where it can often be difficult to decide what is 'reasonable' entertainment. By incorporating scenarios and frequently asked questions to help guide employees, the code can be made into a much more practical document.
7. Supporting framework
The Compliance and Ethics space is currently undergoing many changes - at a regulatory level and also within companies. There is still a high degree of variation in where the compliance function sits between organisations. We've found that the compliance role varies from being a specialist department in its own right to an add-on to a full time role within other functions such as HR and Security.
The code should highlight who the relevant contacts are and provide links to other policies, regulations and organisations that are referred to within the document - making it clear to everyone who they can approach and how they can access the information they need to, no matter where the compliance function sits.
By ensuring all relevant information is contained within a single document makes it easier for employees to know where they can go for support when they need it.
8. Up to date
The code should be relevant and current to the organisation and aligned with changes in the external environment (especially important in highly regulated sectors). We recommend that the code is updated at least every two years. This does not necessarily entail a rewrite of the entire document, but a review to ensure it is still meets the requirements of the organisation and employees.
The process should be transparent and individuals should be able to input their comments and feedback easily. Making the code a living document that incorporates comments ensures its relevance and currency.
9. Context
Many codes focus on the punishments that exist for breaking the rules. However, if people understand why rules are in place, they are much more likely to be aware of the potential consequences of their actions. This in turn, should encourage the 'right' behaviours.
By giving some explanation to the background of the legislation or internal policies, companies can encourage the development of a values and principles (as opposed to a rule based) based culture.
10. Expectations on Individuals
A company's code should be applicable to every employee in the company and should clearly define what the expectations are at the individual level throughout the code. Setting the standards such that behavioural expectations are immediately clear to everyone, especially in highly regulated industries such as banking, is becoming increasingly important.
At our roundtable event in October 2009, 20 participants from various organisations discussed the pros and cons of different Code of Conducts together. You can read more about the outcomes here
