Compliance Standards and Procedures

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Creating a Code of Conduct

You are responsible for drafting your organization’s first Code of Conduct (Code) or replacing an existing Code. Where do you start?

First, determine whether the organization has a rules-based Compliance Program, a values-based Compliance Program or a rules and values-based Compliance Program. What is the difference?

Codes of Conduct Defined

Rules-Based Compliance Program

Employees receive a set of rules to follow—ideally for every situation they may face. Employees do not receive guidance or information about the organization’s values, mission, goals, or ethics. They are told to go to management if they encounter a situation that falls outside the rules.

Values-Based Compliance Program

Employees receive few, if any, rules about how to conduct themselves on the job. The organization describes its values, mission, and ethical framework and tells employees to act accordingly.

Rules and Values-Based Compliance Program

Employees receive rules for frequently encountered and high-risk issues. Employees also receive information about the organization’s values. Employees are told how to resolve issues for which there is no rule by using the organization’s values as their guide.

An organization’s Compliance Program type will largely determine the Code’s structure and content. Because experience indicates that rules and values-based Compliance Programs are most effective, the balance of these guidelines will assume a rules and values-based Compliance Program.[2]

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