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Code of Conduct: Ideas to consider
  • Reduce length and complexity
  • Aim for 5,000 words or less
  •  Emphasize links to policies for in-depth information
  • Add design elements
  • Re-emphasize values and principles (“WHY”)

Communication and training

  • Reconsider the annual certification process
  • Develop a multi-year education plan that includes both communication and training activities
  • Do not forget about  the Board, executives, managers, and third parties – train them targeting individual risks, roles, and responsibilities 
  • Talk about retaliation, encourage questions and “difficult discussions”
  • Productivity goals and incentive should not exert pressure on employees to cross the line
  • Focus on training your compliance officers, especially when the company is diverse or global.
  • Periodic, ongoing communication (e.g., the corporate newsletter, emails, pop-up windows, banners, videos)

Hotline

  • Focus on de-mystifying the compliance hotline
  • Make sure employees are comfortable asking questions and raising concerns 
  • Allow employees to contact the compliance officer directly  
  • Test and evaluation performance of your hotline on a regular basis