Nine Steps for Preparing a New Code

As well as its content and format, the process for drawing up a code of ethics is critical in maximising its influence on business behaviour at all levels and in all functions.

1. Confirm endorsement from the Board
Corporate values and ethics are matters of governance. The board must understand the business case for high ethical standards and attention to integrity risk, and recognise their oversight role in assuring that the organisation lives up to its values.

2. Find a champion
It is good practice to set up a board level (ethics or corporate responsibility) committee, or to assign responsibility to an existing committee (such as Audit or Risk). This will preferably be chaired by a non-executive director who will champion the organisation’s commitment to ethical values. This committee will oversee the ethics function headed by a senior manager responsible for the development of the ethics code, the implementation of the ethics programme and the alignment of all business processes with the ethics policy.
3. Understand the purpose
The oversight committee must clarify the objectives and scope of the ethics programme and ensure that this aligns with the corporate purpose and strategy. It is important to clarify how the organisation’s approach to corporate responsibility, ethics and compliance fit together.
4. Find out what bothers people
Merely endorsing an external standard or copying a code from another organisation will not suffice. It is important to find out what topics employees require guidance on, to be clear what issues are of concern to stakeholders and what issues are material to your business activities, locations and sector. The use of focus groups with stakeholders and employees is helpful here. You may find this Good Practice Guide helpful: Surveying Staff on Ethical Matters
5. Be familiar with external standards and good practice
Find out how other companies in your sector approach ethics and corporate responsibility and what is essential and effective in terms of supporting staff and influencing working practice and culture. Are there national and international standards that you would be expected to observe?
6. Try it out first
A draft code needs piloting - as well as checking that the content provides the guidance needed, work out what terminology and style works best for the code; perhaps with a sample of employees drawn from all levels and different locations.
7. Monitoring and assurance
Consider in advance how the success of the code will be monitored. How will you know the code is working? What are the key indicators/measures of an ethical culture for your organisation?
These resources be helpful:
Code Certification Statements, IBE Briefing 25 (2012)
Living up to our values: developing ethical assurance, IBE (2006).
Investing in Integrity
8. Review
To ensure that new issues are covered and that the code’s relevance is maintained, plan a process of review that will take account of changing business environments, strategy, stakeholder concerns and social expectations, new standards, and strengths and weakness in your ethical performance.
9. Beyond the code
Consider what supplementary materials would support staff to do the right thing.
An example is guidance for decision making (see Ethics in Decision-making, IBE Good Practice Guide) and access to online resources.

How to ...

Ethical values & codes

The core element of an ethics programme will be a Code of Ethics.

Nine steps to preparing a code

The process for drawing up a code of ethics is critical in maximising its effectiveness.

Communicating ethical values

A communications strategy for the ethics programme aims to raise awareness of the organisation’s values.


Ethics training raises awareness around the code, what is acceptable business practice and where support can be found.

More elements of an effective ethics programme

Additional tools and mechanisms to keep the code alive and support staff to apply ethical values to the work they do.

Monitoring & accountability

The board needs to establish a programme of assurance to understand whether the organisation is living up to its ethical values.

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