Embedding codes

09 November 2023

Tags: Code of Ethics

IBE Deputy Director, Rachael Saunders, reports on findings from the recent Business Ethics Network meeting on Embedding Codes

The scope of codes of ethics is evolving.  Data privacy, equality and diversity – as issues come up the priority list for the organisation, they need to be included in the code. 

Many organisations are also evolving how they engage colleagues in the code and how the code is embedded in the ethical culture of the organisation.  Decision making models are one tool to help bring ethical principles to life. 

Tackling barriers to speak up is vital and taking on the feedback from those who have chosen to speak up, as well as those who choose not to make a full complaint after initial contact, can help with learning that can be embedded in a new draft code.  One organisation we spoke to heard from their people that a barrier to speaking up was that they were not sure what would happen next – the new code included more detail on next steps.  It sought to build psychological safety by making it clear that it is not the responsibility of the person speaking up to be sure of every detail of what they are reporting, that mistakes are OK, and that reporting is valued. 

More organisations are using “we” language as part of making the drafting of a code feel more inclusive.  Scenarios are increasingly used alongside the text of the code to bring it to life for all colleagues, with a lot of thought going into different options so that colleagues can choose scenarios that are relevant to their roles and can understand more about the challenges others face by going through scenarios that may be faced by their colleagues. 

Code length is an ongoing debate, as well as format – mobile friendly webpages are widely used, rather than apps, and colleagues can order a hard copy if they need it. 

Some organisations ask employees to attest annually that they have read the code, others require people to undertake mandatory annual training instead.  Badges on achievement of training can act as an effective incentive.  Starting with a set of questions to test understanding and only asking the colleague to undertake training in the areas where they need more knowledge can also help with engagement.  Colleagues can also be asked to attest whether they have reported or spoken up about anything that has been of concern – a positive nudge to encourage speak up. 

Online codes lend themselves to connecting to further resources and each code section can act as a banner for other material that can then be used as content for, say, themed monthly newsletters.  This also enables effective tone from the top as leaders can talk publicly about that month’s topic, such as bribery and corruption or health and safety. 

Some organisations expect all colleagues to undertake training on the code annually, others might have annual ethics training but vary the focus of that training depending on the job role and current areas of focus for the business. 

Engagement with the code can be measured through email opens and clicks – focus groups can also provide valuable feedback. 

A great piece of advice – hold the pen!  There are many stakeholders that need to feed into a code but it is the ethics lead who needs to make sure it is engaging, appropriate, balanced and fit for purpose. 


Rachael Saunders
Rachael Saunders

Deputy Director

Rachael is Deputy Director of the Institute and is responsible for our research programme, and our advisory and training services. She is most interested in how research can generate insights that inspire action. 

Rachael has collaborated with senior leaders across business, charities, communities, local and central government. After gaining her first degree in Politics and History from the University of Durham, and a Masters in Gender and Social Policy from the London School of Economics, Rachael worked in Westminster, then for Carers UK, for UNISON, the public sector trade union, and for the TUC, on skills policy. She was at Business in the Community for over ten years, as an expert in workplace diversity and then in education business partnerships. As a Director at BITC, she worked closely with the Department for Work and Pensions, the then Department for Business, Energy and Industrial Strategy, and business leaders from Aviva, Barclays, Nationwide, UBS, McKinsey and many more.  Her most recent role was on the SLT of Speakers for Schools as it scaled its delivery of opportunities for young people. 

She has held a number of trustee roles including on the board of the Rich Mix Cultural Foundation, the Bromley by Bow Centre and East End Homes. She is currently chair of a charity called Sister System.  She was an elected local councillor for ten years and served as leader of the Labour Group on Tower Hamlets Council. In 2019 Rachael gained an MSc from Birkbeck, University of London, in Business Ethics and Corporate Governance, with a dissertation focussed on how boards communicate their community engagement. 

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