In the compliance world, the Murdoch’s and News Corp continue to provide a veritable plethora of lessons learned. Today we focus on that most basic step of any compliance program – the Code of Conduct. A written Code of Conduct is one of the key components of a best practices compliance program; whether that compliance program is based upon the US Sentencing Guidelines and the Foreign Corrupt Practices Act (FCPA); UK Bribery Act’s Adequate Procedures; or the OECD Good Practices. However, much more than a written Code of Conduct is required for any compliance program to succeed. I do not think that this statement would be news to any compliance practitioner or even controversial, nevertheless it was apparently news to News Corp.