Is it time to update your Code of Conduct?

Many organizations decide to create or update their Code of Conduct when a practical need becomes apparent. Maybe the current guidance is outdated, the operating environment has changed or customer expectations have increased.

However, creating or updating a Code of Conduct should not be done hastily. Before putting pen to paper, the organization should pause to consider its ethical context and what strengthening ethical culture means in that particular organization.

So, what questions should we consider before starting the writing process?

Why?

Why do we need Codes of Conduct? Every organisation has its own reasons for creating or updating a Code of Conduct. The first step is to establish a shared understanding of its purpose:

• Why does the organisation need a Code of Conduct?
• What should the Code achieve? Should it guide behaviour, harmonise practices, fulfil legal requirements or strengthen organisational culture, or perhaps do all of these?
• Have changes within the organisation or its operating environment created a need for new or updated guidance?

The purpose of a Code of Conduct is rarely limited to one objective. It can simultaneously serve as:

• a foundation for the organization’s activities and a promise of how it conducts business
• practical guidance for employees
• a risk management tool
• a message to external stakeholders about how the organisation operates.

Even when the Code serves several purposes, it is important to define its primary objective. Is it mainly intended to strengthen culture, provide practical guidance or support strategic communication?

These choices influence the tone, scope and structure of the document. When the purpose is clear, the Code itself becomes more effective because it is created with that purpose in mind.

Who?

Who does the Code apply to? A Code of Conduct is often written primarily for employees. In reality, however, it may apply to a much wider group:

• employees, management and board members
• subcontractors and suppliers
• agents, consultants and other business partners
• in some cases, customers or communities with which the organisation interacts.

The organization must decide how broadly the scope of the Code should be defined. Should one Code apply to both employees and business partners? Or should external partners have their own ethical guidance, such as a Supplier Code of Conduct, designed specifically for the context of the business relationship? The organization should also consider what commitment to the Code means in practice for each stakeholder group.

Connection to strategy, mission and values

How does the Code connect to your organization’s strategy, mission and values? Ultimately, every Code of Conduct describes what kind of organization the company wants to be and what it aspires to become.

The Code should therefore reflect the organization’s values, strategic priorities, vision, mission and expectations for leadership. A strong Code of Conduct is not an isolated document. It is a natural extension of the organization’s strategy and culture.

• The role of the Code within this wider context can be explored through questions such as:
• How should the Code support a sustainable leadership culture?
• What role should our values play in the Code of Conduct?
• How do our values guide everyday work?
• What kinds of ethical choices does our strategy require?

The Code topics

Which topics should the Code of Conduct cover? Topics that are relevant to almost every organization include:

• safety
• data protection and information security
• anti-corruption and conflicts of interest
• human rights and equal treatment
• speaking up and reporting concerns.

However, every organization needs to ask what is particularly relevant to its own operations. Context matters. For example, safety is important in every organization, but the risks associated with it are different, and potentially more significant, in a manufacturing environment than in an office setting.

A Code of Conduct should therefore be developed using a risk-based approach:

• What ethical risks are connected with our operations?
• What specific characteristics of our business influence our ethical commitments?
• Which legal obligations apply to our activities?
• What do our customers, business partners and other stakeholders expect from us?
• Where are the most significant and likely risks?
• Which risks should we make a particular effort to prevent?

Tip: Consider internal participation from the very beginning of the project. Who in the organization has the best knowledge of the different topics covered by the Code? Involve these people early so that all relevant functions share an understanding of what is being created and why.

Commitment to the Code

How can you strengthen employees’ commitment to ethical conduct? A Code of Conduct is not simply a document, but a tool for guiding everyday conduct and decision-making.

Employee engagement should therefore be considered from the beginning of the writing process:

• How will employees be involved in creating or updating the Code?
• How will the Code be launched?
• How will it be communicated and supported through learning?
• How will the Code be made understandable and accessible?
• How will leaders demonstrate their commitment and lead by example?
• What supporting tools will be needed, such as workshops, eLearning or Q&A sessions?
• How will compliance with the Code, feedback and continuous development be addressed?

Commitment is strongest when the Code feels relevant, concrete and connected to people’s own work, rather than like a mandatory formality.

A well-prepared Code of Conduct serves as a compass for organizational culture and everyday choices. Taking the time to understand the organization’s ethical context makes the result more meaningful and more capable of genuinely supporting ethical conduct throughout the organization.