Innovating Business Ethics: Lessons from refreshing a Code of Conduct

08 June 2022

Tags: Code of Ethics , Ethical Values

In the next blog of the Innovating Business Ethics series, Robert Smith, Director, Business Compliance and Ethics at Serco Group plc, shares Serco's mycode experience.

Ultimately, a company’s values are only as strong as those of its employees. That’s why every employee needs to internalise company values, making them part of every action and decision. Policies are one way to protect organisational values – and reduce risks – by laying out clear rules for employees to follow. But wouldn’t it be better if everyone in a company could make good decisions that reflect a company’s values and ethics, without having to check a company policy? That’s where a strong code of conduct comes in.

A commitment to an effective Code fosters a culture of values-based decision making. It plays an important role in compliance efforts by bridging the gap between values and policies—and by extension, between policies and actual employee behaviour. A Code should provide general behavioural guidelines, ethics-based expectations and a framework for making good decisions that reflect and uphold a company’s values in any circumstance.

Knowing this information puts colleagues in the best situation possible, no matter what scenario they’re facing. It should make them more confident and protect the company from the risks associated with bad decisions. Promoting an effective Code also appeals to a company’s customers and outside stakeholders who increasingly want to know what a company stands for. Finally, a well-defined code of conduct plays an integral role in policy development, training programmes, and other colleague engagement efforts that encourage good behaviour and can reduce the risk of incidents.

Your Code should be the backbone of your compliance program. It should be fully integrated into the consciousness of the company and kept top of mind beyond attestation and training. And up to date!

Keeping a Code up to date can be challenging and was something we had not done for a few years. In 2020 we decided we needed to do a full refresh of Serco’s Code of Conduct and started what would be an 18-month process.

The best place to start is to find out what colleagues think of what you have already. So, during 2021 we engaged various groups of colleagues across Serco reflecting the various markets we operate in and across different roles. What they told us was that whilst they were aware of the Code it was viewed as a management tool and was viewed as impenetrable. Frontline colleagues, therefore, had disengaged perceptions of the code based on their lack of exposure and accessibility. 

We have therefore set about to make our Code feel less intimidating, more easily accessed – and more about them / on their side. That said, of course, the Code must be comprehensive, represent the interests, policies and Values of Serco, and be at the heart of effective training.

The result is mycode. The design of mycode has been based on increasing engagement and making the Code a friendlier, useful tool for when help is needed. We have also tried to make the content relevant to colleagues through real life scenarios. The editorial style has shifted from being (mostly) owned by management to being (as far as possible) owned by employees. 

The full mycode can be accessed online at and, through the site’s accessibility tool, is available in 117 languages. Supporting the online version are a booklet version that explains the key things that need to be known and a wallet card that has the core 10 principles of our code – if you follow them then you will be fine! 

We also took the opportunity to make some technical changes to the content, including adding a specific section on diversity and inclusion; recognising modern slavery and human trafficking alongside human rights; merging working with partners and competitors with working with others; specifically referencing payments in the section on political activity; replacing the section on fraud with accurate records, reporting and accounting; adding a section on tax evasion; and made improvements to our decision-making model.

Reflecting back on the lessons I have learnt from this journey is the importance of starting a conversation. Our view of what we had and the reality were not the same. Through talking with front line colleagues, we found what they wanted and have hopefully created something they will find useful as a regular reference and guide.

Consider the language. We recognised the need for our Code to feel less intimidating, more easily accessed, and more about them / on their side. So invest in a good copywriter who can focus on making the Code a more friendly, useful tool. 

Consider first contact with a clear set of core principles. We have spent a lot of time on the design of the website, but most will first come into contact with it when they join the company. So, the booklet they get is short and clear along with a simple wallet card with 10 principles. If they follow these then they will be fine.

Simplify the online experience. We delivered this through a site that expands and amplifies out from the Core Principles. Whilst it is comprehensive and inclusive, it remains a simple and uncluttered experience with details hidden until required.

Understand your audience. A diverse business-like Serco has many different ‘personas’ within it. Some sit in an office but most are out on the front line of delivering public services. So, in developing your communications and engagement strategy spend time mapping out these different personas and decide how you are going to engage with each group. This created a ‘suitcase’ of online and offline materials for the business to use once mycode had been launched.

Have fun with the design. We specifically didn’t want the website to feel like our corporate website. So, we got permission to use one of the sub-pallet colours within the brand guidelines. We had no photography budget and so we used existing materials but went black and white and cut them out, placing them in different environments with some fun images – this has gone down really well as colleagues feel it is their site and not a corporate rule book – hopefully, a big tick with engagement with mycode.

Take a look and see what you think:


What is the Innovating Business Ethics series?

This year we are publishing a series of blogs exploring the different elements of the IBE Business Ethics Framework - sharing innovative ideas and good practice from a broad range of organisations.

If you would like to contribute to this series please email Alex Johnson.


Robert Smith
Robert Smith

Robert was appointed to the IBE International Advisory Council in 2019.

Director, Business Compliance and Ethics Serco Group plc

Robert joined Serco in 1989, to develop new business within the commercial sector. Over the next 10 years he worked in both business development and operations management. In 1999 he was seconded to the Serco Institute and then joined the Serco Best Practice Centre focusing on operational processes. In 2001 he set up Serco’s Corporate Assurance Group (CAG).

This group, reporting to the plc board, designed and developed the Serco Management System and assumed responsibilities for risk management, ethics, health and safety, environment and internal audit. In 2010 CAG was merged into the Governance Team. Since then Robert has led a review of internal audit which saw a change in our external internal auditors; a review of risk management introducing a risk dashboard and proper development of a Group risk register, a comprehensive review of all company policy and standard’s defined within the ‘Serco Management System’ and clear inclusion of expected processes and controls, revised and reissued Serco’s Code of Conduct and has led a programme focussed on ethical behaviour and understanding, particularly focusing on anti-bribery and corruption following the enactment of the UK Bribery Act. Robert led on several initiatives relating to corporate renewal including the Culture stream of work resulting in the refresh and relaunch of Serco’s values. Robert is Certified Compliance and Ethics Professional (CCEP-I).

Current responsibilities cover health, safety and environment, ethics and elements of ethical compliance covering business conduct and standards of behaviour, anti-corruption and competitive behaviour and human rights.

Robert is a Chartered Director, Honorary Life Fellow of the Institute of Directors and sits on their IoD Accreditation and Standards Committee. He is also a Lay Trustee of the Royal College of Pathologists sitting on the Board and Chairs their Governance and Nominations Committees.

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