Lots done but more to do on FTSE 350 codes

24 May 2023

Tags: Speak Up, Code of Ethics

Reflecting on the findings of FTSE 350 Codes of Ethics: greater clarity needed.

Our analysis of the FTSE 350 codes of ethics was a significant piece of work, and it has been fascinating to see what different organisations have in common, and how they vary.

With 90 of the FTSE 100 having codes, we can now be clear that it is accepted good practice to have and to publish a code of ethics. It is also clearly good practice to keep it up to date, as you would any other important document – and those codes that had been updated in the last three years scored more highly.

Your code is there to set a shared understanding of what is expected, and puts your organisational values into practice, setting out standards and ways of working.

The IBE recommends that a code is principles-based, rather than trying to create rules for every possible situation. A code is a key pillar of building an ethical culture, where people make the right decisions because they know the values and priorities of their leaders and their colleagues around them.

A strong Speak Up culture is a key component of an ethical culture, and it is good to see progress in the number of businesses including speak up and non-retaliation statements in their codes. Fear of retaliation is a genuine barrier to speaking up, and it is only organisations that tackle this that can have any serious hope that they will hear about the issues in their organisations that they need to tackle. 58% of the 189 FTSE 350 publicly available codes have an explicit commitment to non-retaliation. There is room to do better.

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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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