News » Conduct Codes Fall Short in Addressing DOJ Criteria

Conduct Codes Fall Short in Addressing DOJ Criteria

July 22, 2019

Washington, DC - July 12, 2017: United States Department of Justice sign in Washington, DC on July 12, 2017

According to an investigation that looked at 174 codes of conduct randomly selected from Fortune 1000 companies, there is plenty of room for improvement in respect to meeting the effectiveness criteria for corporate compliance programs contained in the latest DOJ guidelines. These are: “Is the compliance program well designed? Is it being implemented effectively? Does it work in practice?” Only 70 percent of the codes of conduct examined included a statement of company values, mission, or key principles. Only 71 percent made it clear that the code applied to executive officers, and only 75 percent mentioned that the code’s tenets were also relevant for the board of directors – as opposed to 96 percent that indicated that employees were to abide by the policies and principles outlined in the codes. The author of the study points out that if employees think a different set of standards applies to senior leaders, then requests made by any senior manager would carry more weight than the nominal principles laid out in the code. Most codes of conduct seem to fall short in this regard. For example, only 52 percent laid out additional responsibilities for managers and supervisors.

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