Code of Conduct Refresh? (ugh!) - Five Top Tips for Success!

/

I’ll admit it. When I was a new CCO, I had absolutely no idea how big an undertaking it would be to publish the company’s first Code of Conduct.  I scheduled about three months – that should be enough to draft the 30 pages or so, get it approved, designed, and published, right?  I hear some of you laughing.  Until you’ve undertaken a Code write or rewrite, you don’t know what you don’t know.  And even if you do know, it can still be shocking when you’re having the sixth meeting about whether the entire gifts and entertainment policy needs to be repeated in the Code or whether the policy can simply be linked from the document.

Creating or rewriting a Code of Conduct can be a daunting prospect, but it can be less taxing and more efficient if you set yourself up for success in the beginning.  Here are five tips to do just that.

No. 1: Create a Working Group of the Willing

Code writing is not a thing to attempt on your own.  You’re setting the tone for the entire company, and it's important to create a document that will resonate with the entire employee population.  A working group populated with people from various functions, geographies, and levels of seniority will help you to get this right. 

Many compliance officers tell people that they will be on the Code rewrite working group.  Instead of telling, try asking.  You want the people on the Code working group to be genuinely interested in the project and to believe that the output is important.  Reading the document three, four, or five times can be tedious, even for people who care about it.  Try to bring in a team that wants to be there.  It’s better to have the mid-level manager of human resources enthusiastically participating than the Chief Human Resources Officer who never sends any comments because they can’t be bothered to sit down with the review copy.

No. 2:  Find Three Codes You Like to be the Guides

Codes of Conduct come in many different styles.  Some are omnibus, containing every compliance- and ethics-related topic under the sun.  Others are streamlined, mostly pointing to company policies and procedures to fill in the details.  Some are loaded with graphics and design elements, while others use the occasional company color, but not much else. 

In order to guide yourself and your team, find three Codes of Conduct that you like to be your guide.  When reviewing them, find the common elements that drew you to your choices.  It’s often easier to find commonality in the Codes you like than trying to define your preferences abstractly.  Review the Codes you like to identify:

  • Tone: On a sliding scale, are you drawn to Codes with a more formal tone, or a more casual tone?

  • Language: Are you drawn to Codes with more legal/complete words, or do you prefer Codes with a lower reading level?

  • Length:  Do you prefer shorter or longer Codes? 

  • Topics:  Do you prefer many topics, and if so, do you prefer them to be covered in-depth or to be covered sparsely? Do you find more than 10 topics to be too much?  Or are you happy with a quick speed through 25 or more topics for completeness?

  • Graphics: What kind of graphics do you prefer?  Pictures of people at work? Swirls or color branding? Cartoon-type images? 

  • Creativity: Do the Codes you chose have links to policies?  Are they modular or presented in a tiled fashion?  Are they mobile-ready? 

Once you’ve identified your preferences, use the examples to guide your working group and your graphic designers.  It’s easier for everyone to work from examples than to work from scratch.

No. 3: Factor in Timing (and cost) for Translations

It’s so easy to underestimate the time and expense of translation.  The first time I got an estimate for Code translation, I almost fell off my chair.  I couldn’t believe it cost as much as it did and would take the number of weeks estimated by the translation company.  By the time I got the third competitive quote, it was clear to me – I had radically underestimated both the time and cost of translation.

When you get your quote, almost invariably, someone in another office will volunteer to translate the Code instead. You will probably want to say yes to save costs.  Don’t.  Translation is a specialist activity, especially when words like “integrity” and “risk-based approach” are translated into languages that might not have easily-understood words for such ideas.

That said, once the translation comes back from the service, ensure that one or more native speakers in your foreign offices review the translation to polish it and make it company-specific.  This also takes time.  Include a period for internal review time in your project timeline.

No. 4: Line up Your Graphics Folks Early

Many compliance officers assume the in-house graphics or marketing team will be able to layout the Code.  In some companies, this is a valid assumption.  If your in-house team can handle the Code layout, great.  Just make sure you book them far enough in advance so they can schedule the time it will take to get a long document formatted.

If your in-house team can’t or won’t do your Code layout, get quotes early from local (or not so local) design firms.  Once again, graphics design can take longer and be more expensive than you think.  Don’t wait for your draft to be complete to bring graphics designers onboard.

No. 5:  Make a Realistic Timeline

You need to plan for time to do many activities on the way to Code publication.  These include:

  • Appointing the members for your working group

  • Creating an outline

  • Getting the working group to agree on the outline

  • Completing the first draft

  • Reviewing the comments of your working group on the first draft, then redrafting

  • Note: this may repeat several times until you have a final working draft

  • Translating by the professional translation company

  • In-house reviewing and revising of professionally translated versions

  • Getting the graphics set-up

  • Completing revisions of the layout and graphics

  • Creating of the communications/training plan for the launch

  • Uploading the Code with links to various sites (internal and external)

I usually tell clients to ballpark six months to a year from beginning to end.  By doing so, they will set realistic expectations for themselves and their organization.

A Code rewrite is a major project that will take more time than most people think.  By keeping in mind these top tips, you’ll set yourself up for success.