Waivers to company codes of ethics have been relatively rare, and when they have been made they have generally been revealed on the corporate Web site rather than in 8-K filings with the Securities and Exchange Commission.

Under SEC rules adopted in January 2003 under The Sarbanes-Oxley Act of 2002, companies are not required to have a code of ethics governing high-ranking officers; however, if they chose not to have one, they must tell the Commission why.