31 Days to a More Effective Compliance Program - Day 6 | The Code of Conduct

Thomas Fox
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What is the value of having a Code of Conduct? In its early days, a Code of Conduct tended to be lawyer-written and lawyer-driven to wave in regulator’s face during an enforcement action as proof of ethical overall behavior. Is such a legalistic code effective? Is a Code of Conduct more than simply your company’s internal law? What should be the goal in the creation of your company’s Code of Conduct?

The three most important things about your See more +

What is the value of having a Code of Conduct? In its early days, a Code of Conduct tended to be lawyer-written and lawyer-driven to wave in regulator’s face during an enforcement action as proof of ethical overall behavior. Is such a legalistic code effective? Is a Code of Conduct more than simply your company’s internal law? What should be the goal in the creation of your company’s Code of Conduct?

The three most important things about your compliance program are “Document, Document, and Document.” The same is true in communicating your company’s Code of Conduct. You need to do more than simply put it on your website and tell folks it is there, available and that they should read it. You need to document that all employees, or anyone else that your Code of Conduct is applicable to, has received, read, and understands it. The DOJ expects each company to begin its compliance program with a very publicly announced, very robust Code of Conduct. If your company does not have one, you need to implement one forthwith.

Three key takeaways:

1. Every formulation of a best practices compliance program starts with a written Code of Conduct.

2. The substance of your Code of Conduct should be tailored to the company’s culture, and to its industry and corporate identity.

3. “Document, Document, and Document” your training and communication efforts. See less -

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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