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Establishing a Global Code of Conduct That Resonates with Employees

By Patricia Colombo, Chief Compliance Officer, FUJIFILM Holdings America Corporation

A Code of Conduct is a cornerstone of any company compliance program, as it sets ethical standards and establishes expectations for employee behavior. Whether a company has 25 or 70,000 employees, a Code of Conduct outlines the organization’s principles and showcases a company’s commitment to a culture of compliance that fosters and upholds the highest ethical standards. Now, some (I’m not included in this list) may say that a code of conduct “may” have a reputation for being somewhat of a boring read, filled with legalese and industry jargon.

So, what good is a global Code of Conduct policy if you view it only as window dressing or a box to check exercise?

It’s crucial that compliance officers and the leadership that are responsible for creating (or enhancing) a Code of Conduct make it not only appropriately structured to manage compliance risks but, provide relevant tools to engage with all employees across your enterprise. In this article, I share how traditional and outdated codes of conduct may be viewed, and how today’s leaders can introduce a Code of Conduct that is visually appealing, engaging and easy to understand so that all employees realize that maintaining high ethical standards is part of their company’s DNA.

How to Develop an Engaging Code of Conduct that Belongs in the 21^st Century

Have your favorite TV shows from the ‘90s aged well? Perhaps you still love the story line for some of these sitcoms, however, they may not be holding up well today given inappropriate cultural references and stereotyping. If you have been putting off updating and/or enhancing your company’s Code of Conduct, perhaps the sitcom reference helps you to realize that your approach to compliance may be similarly outdated.

A code of conduct must be a relevant, living, interactive and employee-friendly resource that is easy to access. Here are some time-tested approaches and tips to translate your Code into actions that protect your company, your employees, and your partners.

• Lead from the top: To create a code of conduct that is truly effective, compliance officers need to solicit feedback and involve leadership from different departments of a company. As we are currently in the process of refreshing our code at Fujifilm, we have established a compliance committee apprised of leadership in corporate communications, legal and compliance, human resources (HR), finance, and more. Having leadership from various departments involved is important to ensure that “voice of customer” influences the finished product, and that messaging and expectations are in line with the company’s core values.
• Reinvigorate the Content: An appealing code of conduct should be more than paragraphs of legal mandates and rhetoric. I recommend organizing the content by topics or behaviors rather than laws. You may also want to include an introduction regarding the purpose of the document, a message from leadership, employees’ responsibilities and the company’s core values. Don’t forget to provide contact information should employees have any questions or concerns.
• Cultivate a Reader-Friendly Tone: Ensure that the code is written in plain language so that readers will easily comprehend and retain critical information. The purpose of the document is to empower employees to make responsible decisions, so include language that provides them the resources and guidance to operate in an ethical and responsible manner.
• Leverage the Power of Technology: ‘Going digital’ will not only appeal to your workforce, but it will make it possible for employees to access information anywhere, anytime. Make sure that any manufacturing employees have easy access to a shared portal, and prominently display on internal “community” bulletin boards.
• Eye-Catching Designs and Examples: This document is as much an employee engagement opportunity as it’s a policy document. Ensure sure your code is on brand with the organization’s values and standard colors, fonts, logos, etc. Also incorporate high-impact, eye-catching designs to dramatically improve usability and utility. Making sure to include real-life examples on what to do and what not to do in and out of the workplace will also add impact to your Code.

Introducing the Code

How an organization introduces its code of conduct is just as important as how it’s written. A great way for it to be shared is to involve the company’s CEO (see Lead from the Top section above) or other leadership unveiling it at a company-wide meeting. I recommend recording the meeting so it can be distributed via an internal newsletter to all employees, particularly for those who could not attend.

Another effective way to create engagement with the code and ensure employee awareness is to develop interactive, mandatory training. Providing employees with convenient online access to code training materials is an extremely valuable component of the educational process. At Fujifilm, we incorporate multi-media in our trainings, so employees can choose whether they would rather read or listen to the program. Additionally, training should include a certification process to verify that each employee has attained an acceptable knowledge and understanding of the code and its application in the work environment.

If your company is global, you and your team will want to create a global taskforce with leadership from key regions. This is important as the code of conduct will need language translations for both the policy and for mandatory employee training. Fujifilm is a global company that spans many industries with 74,000+ employees, and so our compliance team makes sure we take a global approach that is relevant to local requirements as well.

The impact of an engaging code of conduct should not be underestimated. A truly inspiring code reinforces how you conduct business and how you treat others matters, and that your choices and actions define who you are.

Don’t leave it up to others to define that for you.