We don’t have a problem with tone at the top, we have problem communicating the tone at the top. And one of the great missed opportunities is the code of conduct. They are too long and complicated. I have never agreed with the consensus on the structure, purpose and development process for a code of conduct. Years ago most read like a legal document. Luckily those days are primarily over with. However, most codes of conduct are about as inspiring as a restaurant menu. The instruction manual for my car is often more understandable than some codes of conduct. That’s because codes of conduct are often written by technicians, edited by a sea of people and then run through a committee.
If you ever want to suck the life out a document, have it created by committee. If you ever want to make a document much longer than it needs to be, have more people edit it. I agree you have to bring people along by involving them in the compliance program, but let’s do that some other way. Ruining the code of conduct for the sake of bringing people along is just not worth it. It’s the only document of its kind in the organization. And beware of the communications department. They are perfect. Perfection tends to lack inspiration. It’s not their document. The code of conduct needs to be inspiring, and to be inspiring you have to take chances. In fact, I would exclude everyone you can. I would involve one person, your boss or the CEO. And tell them their role is to run interference for you, not edit. Their job is to stop people from ruining your code. Don’t leave others out of the compliance and ethics program development. Bring them all along. Just let them edit all the other documents including the training that affects their area of interest. I would informally get feedback from people about the code but don’t delegate the content to them.
The point is you have only one compliance and ethics document to inspire the employees, and that is the code. It’s the company’s code but it’s the compliance and ethics department’s responsibility to get it right and own it. It should come from the heart. It should set the tone. It should be understandable. There is a Flesch Kincaid reading scale in the spelling checker in Word. Use it and shoot for the lowest grade level you can. I just checked this document and it was at a 5.5 grade scale. Minutes later, as I continued to edit, it went to 6.5. The more you edit and the more people you involve, the more you lose the purpose and simplicity of the code of conduct. You should run your code through Flesch Kincaid and keep checking it as people ruin your document. Here is a tip to achieve a low score on the Flesch Kincaid scale… use small words and short sentences. It’s not hard. Tell the people who want to ruin your code you will not exclude their material. However, you may include it in some other document.
The code of conduct is…
A statement of something the company and its employees aspire to
A message from the leadership
A communication between the compliance and ethics program and the employees
The compliance and ethics departments’ document
A commitment of every employee
Should be marketed as strongly as any product or service the company produces
We don’t have a problem with tone at the top in this country we have a problem communicating the tone at the top. The best code of conduct I ever read was one page. If it’s short…
Everyone could see the code everywhere they go
It can be a part of every handout at every meeting the company conducts
Employees will read it and understand it
3rd parties will read it
It can be in on the wall of every meeting room
It is the apex document for your compliance and ethics program. Treat it like that and don’t use words like apex.
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