Codes of conduct: More than just another policy

Rebecca Walker (, is a Partner in the Santa Monica, California, USA, office of the law firm of Kaplan & Walker LLP.

Compliance practitioners have long described codes of conduct in lofty terms. A quick Google search yielded descriptions of codes as the cornerstone of a company’s ethical culture, the embodiment of a company’s values, and even the heart and soul of an organization. As someone who has written more than her fair share of codes of conduct over the past 25 years, I would love it if all those things were true. However, I’m not quite sure we’re there yet. Too often, codes of conduct are still perceived as merely “required” corporate policies, drafted by legal or compliance professionals, and only dusted off (or clicked on!) during compliance training or disciplinary action. The vision of a “well-worn code” on every employee’s desk was perhaps always a pipe dream.

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