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I would rather not have the CEO just saying all the right things. I don’t think employees measure the CEO or top management by what they say they measure what they do.

I am less of a fan of codes of conduct than many others are. I almost never disagree with Dick Cassin, but I would like to suggest a different approach regarding codes of conduct. Cassin is the publisher and editor of the FCPA Blog.Ī version of this post first appeared in Compliance Management Magazine and is republished here with permission.

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The reason, after all, is accountability.Īre we acting honorably? Or are we falling short? Let’s measure ourselves against the Code of Conduct. So it’s crucial to be clear and personal when telling employees and others why there is a Code of Conduct and how it should impact our daily lives.

Umpleby says one document - the Code of Conduct - is the most important. Any big company produces a lot of documents every day. In his introduction to the company’s Code of Conduct, he says: “I think our Code of Conduct is the most important document we produce at Caterpillar.” Wow. Mine, yours, ours.Īn even stronger statement comes from Jim Umpleby of Caterpillar. And he gives responsibility to each employee. The responsibility lies with all of us - it’s mine, it’s yours, it’s all of ours.

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Acting with integrity depends on each of us giving our full commitment. Our commitment to doing the right thing, which means complying with both the spirit and the letter of the laws that govern our industry, gives us a competitive advantage. In the preamble of Pfizer’s Code of Conduct, he says, They fall a bit short of being genuinely human and personal.Ĭompare ThyssenKrupp’s words with the message from Ian Read, the chairman and CEO of Pfizer. I like the use of the word “promise.”īut to be honest, ThyssenKrupp’s words are rather “industrialized.” Somehow they lack. It set out the expectations for behavior. The letter says the Code of Conduct “sets a standard for ourselves and at the same time represents a promise that we will act responsibly both externally in our dealings with business partners and the general public as well as internally in our interactions with colleagues.” That’s good. That accountability is one way the mere presence of a strong and clear Code of Conduct helps drive compliance forward.īecause Codes of Conduct send such a powerful signal to employees and others, often the most important words in the code come at the beginning - in the introduction, or the CEO’s letter, or the prelude.įor example, ThyssenKrupp’s Code of Conduct is introduced by a letter from the company’s Executive Board. Then it acts as a gauge for accountability, a way to measure if we are honorable or if we are hypocrites. It tells the stakeholders and the rest of the world what our standard of behavior must be. The Code of Conduct is like a flag that declares what we stand for. If we don’t live up to those beliefs, then we’re hypocrites. If we live up to those beliefs, we have behaved honorably. Once we tell other people what we truly believe, then we become accountable. And this is how our company and everyone in it is expected to behave.” The act of declaring publicly what we believe sets the course of our behavior. There’s something powerful in a simple statement that says, “This is what I believe. The Code of Conduct is a statement by top management – the chairman or CEO – about what the company truly believes. And so on.īut there’s something even more important and deeper than those rules. Here’s the company position about conflicts of interest.