A thoughtful and well-drafted Code of Conduct is the cornerstone of any strong corporate compliance program. Making that cornerstone strong enough to support a compliance program worldwide, spanning all manner of cultures—that’s the tricky part.
Some companies take a values-based approach, where they lay out a set of principles in their Code as a guide that maintains flexibility for distinct local cultures. Others follow a more prescriptive approach, spelling out both the company’s core values and then delving into specific rules of law. (Highly regulated businesses may not have much choice but to adopt the latter.)
