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For a summary of how to make a code effective: click
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A policy and code will only be effective in influencing decisions
if they are accompanied by a wider programme to reinforce
a culture of ethics. The programme for integrating the code
into the running of the business needs to be promoted at the
time that the code is issued.
This programme might involve awareness raising; understanding;
leadership example; and monitoring. Below are some suggestions
for this.
a) Communication and Awareness Raising
- Send the code, or a summary of it, to all employees in
the company and to new employees as part of the induction
process.
- See that the code is translated for use in overseas subsidiaries
or other places where English is not the principal language.
Ensure that the code is communicated in a way that is compatible
with local culture.
- Use all available communication channels to raise awareness
of the policy and code.
- Ensure that employees are aware of the consequences of
breaching the code.
- Ensure that employees are aware of how to make enquiries
or to report suspected breached of the code.
- Make copies of the code available to business partners
(suppliers, customers etc.) and explain how they need to
comply.
- Reinforce an ethical culture with reports in newsletters
on ethical issues and dilemmas faced by the organisation
and its employees.
- Consider the use of desktop gimmicks to remind staff of
ethical values.
b) Understanding Through Training
The aim is to raise the ethical sensitivity of staff so that
they know when a decision which they face involves an ethical
choice and how they can find support for their decisions.
They will also be clear about what is acceptable business
practice and what is not, and why ethics and integrity are
important to their organisation. They will want to know why
and how ethical conduct is relevant to their jobs.
- Include ethical issues in all training programmes.
- Ensure that all levels of staff, including the Board,
are trained to understand the ethics code and policy and
how they work.
c) Cultural Reinforcement
A code and policy will be most effective in their aims where
a culture of high ethical standards exists and is reinforced
consistently across the organisation.
1. Leadership example
- Make sure that the code is endorsed by the Chairman
and CEO, but also that all senior staff are aware of the
importance of example in establishing normal business
practice.
- Ensure that staff are aware that the Board takes ethical
values into consideration when formulating strategy for
the business
2. Contracts and reviews
- Consider making adherence to the code obligatory. For
instance, include a reference to it in contracts of employment
and link it with disciplinary procedures.
- Make reinforcement of or acting in accordance with an
ethical culture an element of staff development reviews
and bonus and salary evaluations.
- Consider having a self-certification procedure for managers
and supervisors regularly to state that they and their
staff understand and apply the provisions of the code.
3. Speak Up
- Promote a speak up policy and
procedure that employees are confident in
- An employee should know how to react if he or she is
faced with a potential breach of the code or is in doubt
about a course of action involving an ethical choice.
d) Governance, Monitoring and Accountability
1. Governance
- It is good practice to establish a board
level committee with oversight for establishing, reinforcing
and monitoring the ethics policy and identifying ethical
risks and opportunities.
2. Monitoring & Assurance
- The board needs to establish a programme of assurance
to consider the extent to which the organisation is living
up to its ethical values. Consider by what criteria
performance will be assessed. Tools include staff surveys
and establishing performance indicators for each section
of the code of ethics.
- Consider any external standards with which you wish
to comply.
- The board should receive regular reports on ethical
performance, ethical issues, breaches of the code and
use of speak up lines.
3. Regular Review
- The code of ethics and ethics programme should be regularly
reviewed at least every three years to ensure that new
issues are covered and that its relevance is maintained.
4. Reporting
- Identify audiences that will need to be informed of
your ethics performance.
- Consider how to maximise the credibility of any reporting.
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