Code of Conduct, Compliance Policies and Procedures-Part IV

This is the fourth and final installment of my series on the the importance of a Code of Conduct and anti-corruption compliance policies and procedures in your compliance program and how you should go about drafting or updating Code of Conduct and anti-corruption compliance policies and procedures.

On Tuesday, I reviewed the underlying legal and statutory basis for the documents as a foundation of your overall anti-corruption regime. In subsequent posts, I looked at how to go about drafting your Code of Conduct and anti-corruption compliance policies and procedures. Today, I will end the series on how to keep all of the above vibrant and dynamic through a discussion of how to assess, review and revise them and your Code of Conduct on a timely basis.

Simply having a Code of Conduct, together with policies and procedures is not enough. As articulated by former Assistant Attorney General, for the Criminal Division of the US Department of Justice, Lanny Breuer, “Your compliance program is a living entity; it should be constantly evolving.” In an article in the SCCE Magazine, entitled “Six steps for revising your company’s Code of Conduct”, authors Anne Marie Logarta and Ruth Ward suggest considering the following issues before you take on an update of your Code of Conduct.

  • When was the last time your Code of Conduct was released or revised?
  • Have there been changes to your company’s internal policies since the last revision?
  • Have there been changes to relevant laws relating to a topic covered in your company’s Code of Conduct?
  • Are any of the guidelines outdated?
  • Is there a budget to create/revise a Code?

After considering these issues, the authors suggest that you should benchmark your current Code of Conduct against others companies in your industry. I would also add that your standards, policies and procedures should be reviewed and updated in the same manner ...

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