When it comes to revising your Code of Conduct, the Justice Department’s Evaluation of Corporate Compliance Programs provides a good starting point by asking the following questions: What has been the company’s process for designing and implementing new policies and procedures? Who has been involved in the design of policies and procedures? Have business units/divisions been consulted prior to rolling them out? Based on these questions here are some steps to follow to help you think through the process.

Thomas Fox has practiced law for over 40 years. Tom writes the daily award-winning blog, the FCPA Compliance and Ethics blog and founded the Compliance Podcast Network. Tom leads the discussion on AI in...