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   * Catalyst Reveal - Analytics
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9 ETHICAL CODE OF CONDUCT EXAMPLES FOR THE 2023 BUSINESS PROFESSIONAL

Program Effectiveness By Jim Walton
Aug 07 2023 • min read

The code of conduct has undergone an evolution over the last 20 years. Once
written as textbook-sized rule books, today's best code of conduct examples are
visually engaging, readable, and useful to employees as guides to help them make
ethical decisions and do the right thing. Good codes of conduct provide a
behavioral framework for individual business professionals, teams, leaders, and
organizations regardless of affiliation, level, or geography. They also leverage
advanced technology for easy access, better employee engagement, and
just-in-time insights for navigating the grey areas that are inevitable in the
new world of work. 

But what exactly is a “good” code of conduct example? To break the goals into
more actionable practices and identify ethical code of conduct examples that
were effective, LRN assessed nearly 200 codes of conduct from some of the top
companies headquartered in Europe, Japan, Singapore, and the United States. The
result of our research, the 2023 LRN Code of Conduct Report, looks at company
codes from the top 30 to 40 organizations in the CAC (France), DAX (Germany),
FTSE (UK), NIK (Japan), SGX (Singapore), and S&P (USA) stock exchange listings.

Let's dive deeper into nine code of conduct examples that we came across in our
analysis, each of which scored the highest on the dimensions our report
identified as key to an effective code. 


LRN CODE OF CONDUCT REPORT DEFINITIONS OF CODE DIMENSIONS 

We used LRN’s proprietary Code of Conduct Assessment Tool to yield a concrete,
objective, and comprehensive measurement of excellence based on 47 questions
that map to eight dimensions of code of conduct effectiveness. The dimensions
include: 

 * Tone from the Top: An inspiring message from senior leadership that
   demonstrates a commitment to ethical behavior and living the values of the
   organization. 
 * Purpose and Values Orientation: A clear statement of what the company values
   are and how they translate to behavioral expectations for how employees treat
   one another, customers, and the communities they serve. 
 * Applicability and Administration: Defining to whom the code applies and how
   it’s implemented and enforced. 
 * Speaking Up: A summary of the reporting channels available to employees and a
   description of the process for addressing concerns raised. 
 * Risk Topics: High-level guidance of the risks within the organization and
   wider industry, along with principles and standards employees can follow to
   help avoid or manage these risks. 
 * Knowledge Reinforcement: Integrated learning aids—e.g., real-life scenarios,
   ethical decision-making models, links to policies, and links to resources
   such as training and videos—that are easy to refer back to in the code. 
 * Usability: Making the code accessible to all employees through easy
   navigation, readability, and content structure. 
 * Look and Feel: Making the code a visually engaging reflection of the
   organization’s brand, including use of imagery and graphics to enhance
   readers’ comprehension of material. 

 


9 ETHICAL CODES OF CONDUCT THAT SCORED HIGHEST ON EACH DIMENSION OF
EFFECTIVENESS 

Below are the company codes of conduct that scored highest on each dimension,
plus examples of codes that exemplified a great mix of all dimensions and were
considered effective overall.

 * Dimension 1 – Tone from the Top: 3M
 * Dimension 2 – Purpose and Values Orientation: Barclays
 * Dimension 3 – Applicability and Administration: Coca Cola
 * Dimension 4 – Speaking Up: Amgen
 * Dimension 5 – Risk Topics: Imperial Brands
 * Dimension 6 – Knowledge Reinforcement: Air Liquide
 * Dimension 7 – Usability: Glencore
 * Dimension 8 – Look and Feel: CRH
 * Overall effectiveness: General Motors, 3M, Hoya Corporation

Note: Some companies have made adjustments to their code since LRN's initial
analysis.


TONE FROM THE TOP: 3M 



Why this code works 

 * The leadership message is inspiring for the employees.
 * Readability rating is high, which means that the language is accessible for
   all employees and generally avoids legalistic or technical terms.
 * The code references the organizational purpose of the company, connects to
   the company values, and emphasizes company values throughout. 
 * Images and graphics enhance the reader’s experience.   

What could be improved 

 * The code could add an explanation of how it heightens sensitivity to ethics
   and compliance risks, enhances decision making, and helps strengthen culture.
   It could also have an ethical decision-making model that incorporates
   organizational values in a meaningful way.   
 * The code could add an explanation of the code’s role in the greater E&C
   program.  
 * The code could give a more detailed explanation for the procedure of the
   investigation of alleged misconduct.   

 


PURPOSE AND VALUES ORIENTATION: BARCLAYS 



Why this code works 

 * The leadership message is inspiring for the employees. 
 * The code references the organizational purpose of the company, connects to
   the company values, and emphasizes company values throughout. 
 * The code has a distinct theme that connects specifically to the
   organization’s purpose, brand identity, and business activities. The theme is
   carried throughout the code. 
 * The code’s content is structured according to clear and logical organizing
   principles, with images and graphics that enhance the reader’s experience. 

What could be improved 

 * The code could make a more detailed reference to leaders' and supervisors'
   having additional responsibilities related to E&C—e.g., being the first point
   of contact for raising issues, listening up, leading by example—with an
   emphasis on their role as "carriers" of the culture and values.  
 * The code could identify additional resources for seeking guidance, raising
   concerns, and reporting violations. It could also provide additional helpline
   details including more information regarding confidentiality and anonymity.
 * The code could add more risk topics consistent with the organization’s
   industry and sphere of operations. Also, it could more clearly state the
   business rationale for giving guidance regarding risk topics.
 * Individual code provisions could follow a more consistent structure to aid
   clarity and readability for the user.  

 


APPLICABILITY AND ADMINISTRATION: COCA COLA 



Why this code works 

 * Readability rating is high, which means that the language is accessible for
   all employees and generally avoids legalistic or technical terms. Tone of
   voice is also inclusive, using words “we,” “us,” and “our.” 
 * The code is expressly applicable to all employees, officers, directors, and
   contractors. It makes specific reference to employees’ responsibility for
   following the code and to leaders’ and supervisors’ additional E&C
   responsibilities.   
 * There are multiple resources for seeking guidance, raising concerns, and
   reporting violations. There are helpline details along with steps to address
   issues of confidentiality and anonymity. The code also indicates that proven
   retaliation will result in disciplinary action.   
 * The code has a distinct theme that connects specifically to the
   organization’s purpose, brand identity, and business activities. The theme is
   carried throughout the code.
 * The code’s content is structured according to clear and logical organizing
   principles, with images and graphics that enhance the reader’s experience.
 * The code has navigation and highlights behavioral expectations, important
   resources, and the essential principle of each provision.
 * The code has scenario-based Q&A’s.   

What could be improved 

 * The code could have a leadership message that is concise and addresses unique
   aspects of the organization, inspiring employees and connecting to values and
   business performance.   
 * The code could better highlight organizational values, explain their
   significance, articulate them in behavioral terms, and integrate them
   throughout. 

 


SPEAKING UP: AMGEN 



Why this code works 

 * The code references the organizational purpose of the company, connects to
   the company values, and emphasizes company values throughout. 
 * The code is expressly applicable to all employees, officers, directors, and
   contractors. It makes specific reference to employees’ responsibility for
   following the code and to leaders’ and supervisors’ additional E&C
   responsibilities.
 * There are multiple resources for seeking guidance, raising concerns, and
   reporting violations. There are helpline details along with steps to address
   issues of confidentiality and anonymity. The code also indicates that proven
   retaliation will result in disciplinary action.
 * The code’s content is structured according to clear and logical organizing
   principles. Individual provisions also have a consistent structure designed
   for readability and clarity of guidance.
 * The code has scenario-based Q&A’s and contains an ethical based
   decision-making model that incorporates organizational values in a meaningful
   way. 

What could be improved 

 * The code could better highlight organizational values, explain their
   significance, articulate them in behavioral terms, and integrate them
   throughout.  
 * The code could have a more distinct theme that connects specifically to the
   organization’s purpose, brand identity, and business activities.  
 * The code could have a more comprehensive range of risk topics, consistent
   with the organization’s industry and sphere of operations.   
 * The code could use more graphic design and imagery to enhance visual impact,
   use more call-out boxes to emphasize key content, reduce large blocks of
   text, and improve layout and formatting for a more consistent visual style
   with the organization's brand identity. 

 


RISK TOPICS: IMPERIAL BRANDS 



Why this code works 

 * The code references the organizational purpose of the company and connects to
   the company values. In addition, the code explains the significance of the
   values, articulates them in behavioral terms, and integrates them
   throughout.  
 * The code makes specific reference to leaders’ and supervisors’ additional E&C
   responsibilities.
 * The code addresses a wide range of risk topics and the business rationale for
   giving guidance is clearly stated.
 * The code’s content is structured according to clear and logical organizing
   principles, with important resources displayed prominently. Individual
   provisions also have a consistent structure designed for readability and
   clarity of guidance.
 * The code’s visual style is consistent with the organization’s brand. Images
   and graphics enhance the reader’s experience, text call-out boxes emphasize
   key content, and content layout avoids large blocks of text which could
   hinder reading.
 * Readability rating is high, which means that the language is accessible for
   all employees and generally avoids legalistic or technical terms. Tone of
   voice is also inclusive, using words “we,” “us,” and “our.” 

What could be improved 

 * The code could be more expressly applicable to all employees, officers,
   directors and contractors.  
 * The code could explain how it heightens sensitivity to ethics and compliance
   risks, enhances decision-making, and helps strengthen culture.   
 * The code could identify additional resources for seeking guidance, raising
   concerns, and reporting potential violations. It could also provide more
   helpline details and steps to address issues of confidentiality and
   anonymity. 

 


KNOWLEDGE REINFORCEMENT: AIR LIQUIDE 



Why this code works 

 * The leadership message is inspiring for the employees. 
 * The code references the organizational purpose of the company and its
   relationship to day-to-day business operations.
 * The code identifies resources for seeking guidance, raising concerns, and
   reporting potential violations. It also addresses a comprehensive range of
   risk topics consistent with the organization’s industry. 
 * The code’s content is structured according to clear and logical organizing
   principles. Individual provisions also have a consistent structure designed
   for readability and clarity of guidance.
 * The code highlights behavioral expectations, important resources, and the
   essential principle of each provision.
 * Images and graphics enhance the reader’s experience, text call-out boxes
   emphasize key content, and content layout avoids large blocks of text which
   could hinder reading. 

What could be improved 

 * The code could better highlight organizational values, explain their
   significance, articulate them in behavioral terms, and integrate them
   throughout. 
 * The code could make specific reference to leaders' and supervisors'
   additional E&C responsibilities. 
 * The code could provide more detail into the investigation process of alleged
   misconduct. 
 * The business rationale for giving risk-related guidance could be more clearly
   stated. 



USABILITY: GLENCORE 



Why this code works 

 * The leadership message is inspiring for the employees.
 * The code references the organizational purpose of the company and its
   relationship to day-to-day business operations.
 * Readability rating is high, which means that the language is accessible for
   all employees and generally avoids legalistic or technical terms. Tone of
   voice is also inclusive, using words “we,” “us,” and “our.”
 * The code is expressly applicable to all employees and makes specific
   reference to leaders’ and supervisors’ additional E&C responsibilities. 
 * The code contains an ethical based decision-making model that incorporates
   organizational values in a meaningful way and directs employees to company
   policies. 
 * The code identifies resources for seeking guidance, raising concerns, and
   reporting violations. It also provides helpline details and addresses a
   comprehensive range of risk topics. 
 * The code’s content is structured according to clear and logical organizing
   principles, with important resources displayed prominently. Individual
   provisions also have a consistent structure designed for readability and
   clarity of guidance.
 * The code highlights behavioral expectations, important resources, and the
   essential principle of each provision.
 * The code’s visual style is consistent with the organization’s brand. Images
   and graphics enhance the reader’s experience, text call-out boxes emphasize
   key content, and content layout avoids large blocks of text which could
   hinder reading.  

What could be improved 

 * The code could have a more distinct theme that connects specifically to the
   organization’s purpose, brand identity, and business activities and carry it
   throughout. 
 * The business rationale for giving risk-related guidance could be stated more
   consistently across code provisions.
 * There could be more scenario-based Q&A’s.   

 


LOOK AND FEEL: CRH 



Why this code works 

 * The leadership message is inspiring for the employees. 
 * The code references the organizational purpose of the company and its
   relationship to day-to-day business operations. It also references
   organizational values and integrates them throughout the code. 
 * The code has a distinct theme that connects specifically to the
   organization’s purpose and brand identity. The theme is carried throughout
   the code. 
 * The code’s visual style is consistent with the organization’s brand. Images
   and graphics enhance the reader’s experience, text call-out boxes emphasize
   key content, and content layout avoids large blocks of text which could
   hinder reading. 
 * The code highlights behavioral expectations, important resources, and the
   essential principle of each provision. 
 * Individual code provisions have a consistent structure designed for
   readability and clarity of guidance. 

 What could be improved 

 * The code could better highlight organizational values, explain their
   significance, articulate them in behavioral terms. 
 * The code could provide more detail into the investigation process of alleged
   misconduct.

 


OVERALL EFFECTIVENESS: GENERAL MOTORS, 3M, HOYA CORPORATION 



Each company code of conduct exemplified a great mix of all eight dimensions of
code effectiveness.  

 * General Motors: The visual display of the General Motors Code is very
   consistent with the brand identity. Their distinct theme, “Winning with
   Integrity,” connects specifically to the organization’s purpose and
   brand. The values are prominently displayed and explained in detail. The risk
   provisions have a consistent structure that is designed for clarity of
   guidance. The code also highlights the behavioral expectations and other key
   points in each provision. The readability rating is high, which means that
   the language is accessible for all employees and generally avoids legalistic
   or technical terms. There is a high usage of graphics and imagery to enhance
   the reader’s experience and make the visual stye consistent with the
   organization’s brand.   

 * 3M: Beginning with the cover, the 3M Code visually jumps out at you. The
   theme “Be 3M” is in large bold letters, making it the first thing the reader
   sees. The cover also features the values, which expand on the theme: Be Good;
   Be Honest; Be Fair; Be Loyal; Be Accurate; Be Respectful. The language of the
   code is crisp and clear throughout, reflecting the unique voice of 3M. The
   code is organized according to the values, and the subtopics under each value
   bring additional clarity and detail to what it means to live each value. The
   layout is very clean, with an abundance of white space making it easier to
   read. The code also highlights key principles and uses brand colors and
   iconography to not only make it easy to find information, but make it feel
   like 3M. 

 * Hoya Corporation: Hoya Corporation’s code of conduct starts out with a very
   strong tone-from-the top message from the CEO. It has an engaging theme that
   is carried throughout the document. The code makes a strong connection to
   business purpose and values, and references to the values are integrated
   throughout the code. Hoya’s code provides employees with comprehensive
   information about the various methods available for employes to raise
   concerns and seek advice. The look-and-feel of the Hoya code is very unique
   to Hoya and makes it easy for employees to comprehend its key messages and
   quickly find the information they are looking for. 


THE KEY TAKEAWAY 

These are just some examples of a code of conduct that effectively communicates
company values, ethical standards, and professional expectations. Using a mix of
clear messaging, engaging visuals, simple content structure, and easy navigation
can make a significant impact on how an organization’s code performs against
each dimension of code effectiveness. To learn how you can enhance your own
company code of conduct, download a copy of the 2023 LRN Code of Conduct Report
and explore our collection of code resources.   

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