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
Your company’s highest level must give the mandate for a revision to a Code of Conduct. It should be the chief executive officer, general counsel, or chief compliance officer, or better yet all three to mandate this effort.
Establish a core revision committee
Create a cross-functional working group should head up your effort to revise your Code of Conduct. It can include representatives from the following departments: legal, compliance, communications, HR; your domestic and international business units; finally, finance and accounting, IT, marketing, and sales.
Conduct a thorough technology assessment
The foundation of the revision process is how your company captures, collaborates and preserves the decisions during the revision. Utilize the technology available to you to do so, which will come into pay in your distribution plan.
Determine translations and localizations
The Justice Department and the Securities and Exchange Commission require a local language component. Use translations experts. Everyone must have the same understanding of the company’s Code-no matter the language.
Develop a plan to communicate the Code of Conduct
Use the full panoply of tools available to it to publicize your revised Code of Conduct at roll-out. This can include a multi-media approach or physically handing out a copy to all employees at a designated time. You might consider having a company-wide Code of Conduct meeting where the revised Code is rolled out across the company all in one day.
Stay on Target
If you set realistic expectations you should be able to stay on deadline and stay within your budget. Do not be distracted by other issues that might arise during the process.