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.
Get buy-in from decision makers at the highest level of the company
