1. Introduction:
- Statement by the CEO/President of his commitment to the code, and a promise to act consistently with it
- Explanation of why the code is being promulgated, to whom it applies, and how it is to be used
- Statement that legality is necessary but often an insufficient standard of ethical conduct
2. Core values/cultural philosophy:
- Organization’s vision or mission statement
- Guiding “moral/ethical” principles such as honesty, respect, fairness
- And “pragmatic/organizational” principles such as excellence, quality, customer satisfaction, sustainable development
3. Elements of the code:
- See ‘Elements of an Ethics Code’
- Specific policies expanding element headings (such as conflicts of interest, records keeping, antitrust, insider trading, discrimination/harassment, health/safety, environmental)
- References to applicable professional ethics codes
- Behavioral examples of the very types of dilemmas that an employee might encounter
- Statement that such illustrations are not intended to be inclusive or limiting
4. Supporting infrastructure:
- Where to find more information or go for interpretation (such as an immediate supervisor, ethics office, or legal counsel)
- Reporting violations via the Ethics Hotline
- Statement on the organization’s commitment to confidentiality and non-retaliation for the use of any of the supporting systems
5. Personal responsibility:
- Statement that it is each individual’s responsibility to know and understand the requirements and expectations set forth in the code and to meet those standards
- Statement that employees must report suspected violations of the code, and that failure to do so is itself a violation
- Affirm the potential for disciplinary consequences including dismissal as well as legal action (resulting in civil or criminal penalties) for code violations
- Acknowledgement form
- Statement that failure to read the code or sign the acknowledgement form does not excuse an employee from the standards