How a code of conduct reflects culture and meets DOJ requirements

5 minute read

Every compliance program begins with a code of conduct. The code of conduct expresses a company’s fundamental values and its commitment to living by them. Although a code of conduct is usually a very high-level document, it expresses values in very specific areas of interest to a company, from which more detailed policies and procedures follow. Those values may vary from industry to industry because the business activities of an industry may necessitate more emphasis on particular values. Those values may also vary because corporate leadership may have different priorities as well.

Through the U.S. Sentencing Guidelines and public guidance, the U.S. Department of Justice (DOJ) has expressed its view about important elements of a compliance program. The DOJ expects a compliance program to be “well-designed . . . adequately resourced . . . [and] work in practice.”[1] Recent guidance has directed companies to ensure their compensation schemes reward compliance functions and successes and impose significant financial penalties on those who engage in misconduct.[2]

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