This document discusses developing, implementing, and measuring an effective code of conduct. It provides examples of companies that have both succeeded and failed at this. United Airlines' code did not reflect its values, leading to problems. Lehman Brothers' code focused only on rules rather than ethics. Microsoft eliminated most policies and ensured its values were reflected in all aspects of business through management training and transparency. The document stresses that an effective code requires thoughtful, strategic, and scientific development, implementation through training and culture, and measurement using climate surveys, audits, and benchmarks.

1. A Campus-Wide Approach to
Sexual Assault Prevention
February 14, 2017
From Paper to Action: Using a
Code of Conduct Effectively
Douglas Kelly
Lead Legal Editor
Corporate Compliance &
Financial Education

2. AGENDA
1. Development and Improvement
2. Implementation
3. Measurement

3. Case Study:
United Airlines
Values Not Reflected in Code of Conduct
“Our review shows that many things went
wrong that day, but the headline is clear: our
policies got in the way of our values and
procedures interfered in doing what’s right.”
- CEO Oscar Munoz
SEC: Violating Code of Conduct Violates Law

4. DEVELOPMENT
& IMPROVEMENT

5. The Legal Stuff
Evaluation of Corporate Compliance Programs
- Applicable Policies and Procedures
- Gatekeepers
- Accessibility

6. What Needs
to Improve
Mission Statement
(what company stands for)
Core Values
(create attitudes desired)
Responsibilities
(what everyone needs to DO about it)
Norms
(Formal and Informal)

7. Case Study:
Lehman Brothers
compete aggressively in furthering the interests of the firm
“The Lehman code of ethics and internal code of conduct do
not offer much vision or guidance to the reader. . . . While it
lays out the basic rules expected of all Lehman employees,
executives missed the opportunity to create a unique code
expressing strong ethical principles. . . The Lehman code did
a basic job of protecting the organization against illegal
actions by employees, but it did little to advance an ethical
culture that might have sustained them.”

8. Reevaluate.

9. IMPLEMENTATION

10. Operations
Recruitment & Retention
Brand
Product
Third Party Relationships
Customer Service
Human Resources
Strategy

11. Culture
Tone from the Top
Management
Legitimacy
Daily Actions
Values + Reporting
Training
Six Elements of a Compliance Culture

12. Training
Tone
Immediate Utility
Engagement
Reinforcement
The Value of Conduct Training

13. Case Study:
Microsoft
Microsoft Runs on Trust Campaign
- Eliminated 90% of Policies
- Values Reflected in All Aspects of Business
- Management Training
- Transparency
Ethisphere. (2017). Peeking Through the Windows.

14. It starts with you.

15. MEASUREMENT

16. Climate Survey
Harvard Business Review
Study on Google’s Project Oxygen
Ethisphere
What companies are asking.

17. Triangulation
Internal Audit
Hotline
Training

18. The Follow Up
Identify Risks
Act off Benchmarks
Reporting

19. This is definitely possible.

20. Main Takeaways
Thoughtful
Strategic
Scientific

21. About EverFi
Acquired LawRoom in 2016 and
Workplace Answers in 2017, online
compliance training providers.
Content team includes instructional
writers, designers, attorneys, to
ensure accuracy, effectiveness.
Research team of data analysts,
lawyers, and scientists.

22. Questions

23. Contact
Michele Collu
Demand Generation Manager
mcollu@everfi.com