Creating a user-friendly code of ethics
Written by Steve Donovan and the Compliance team at International Paper
At International Paper, we recently overhauled our code of ethics. We wanted the update to not only outline rules and expectations, but also be user-friendly and support a larger drive to promote and reinforce our ethical culture. Here are a few things we learned on the journey to total code makeover.
If you build it, will they read it?
When creating or revising your ethical code, where should you start? You already know to incorporate benchmarking and best practices, address respect and dignity, and include “no retaliation” language. But what about pictures? Should you print your code or post it online? Can you make it into a document that employees will actually read? You expect everyone to follow your code, so show them it is important by investing the resources to make it professional, engaging, and relevant to their day-to-day challenges on the job.
First things first.
What should you name your code? Our previous version was the International Paper Code of Business Ethics, a title that seems to say, “Here’s what our standards are.” There’s nothing wrong with that, but we wanted to shift the focus to communicate, “Here is how you are expected to act.” So we named our update the International Paper Code of Conduct.
The executive plug.
About that introduction from the CEO: While researching other company codes, we noticed some included this as a separate cover letter, while others made it part of the document. In our previous version, we had tucked it in as a loose letter inside the front cover, but it easily became separated. In our update, we put it on page 1, even before the table of contents, reinforcing the “message from the top” as both up front and integral. However, consider your company’s circumstances and how they may affect placement. If your CEO is planning to retire soon, you may not want this introduction immortalized—and immobilized—in your code for the long haul.
Get a writer.
This is not the time to use GRE and LSAT vocabulary or demonstrate how many instances of passive voice you can string together in a single sentence. Hire a writer who can turn that legalese into prose that is clear, succinct, and accessible to your average high school graduate. It doesn’t have to read like Harry Potter, but it should be a smooth read for your entire employee base. Also, use section names rather than page numbers for cross-referencing, since page numbers change with ongoing revisions. For example, say, “For a list of HelpLine resources, see Using the HelpLine,” rather than, “see page 23.” This will make writing and proofing less tedious.
Beef it up. Mix it up. Break it up.
Naturally, your code will address rules, laws, and the consequences for violating them. However, don’t stop there. Give case scenarios: Maria just found sensitive competitor information. What should she do? A supplier sent concert tickets to Alex. Can he accept them?
You can also engage your readers with callouts, short quizzes, resources, and Q&As placed strategically throughout the document; don’t just stick a quiz and resources section at the end. Variety can keep your code from becoming monotonous.
The proof is in the proofing (sic.).
Get multiple people to proofread your code again and again. Don’t rely on the same handful who are so entrenched in it and have read it so many times that they can no longer see where “manager” is spelled “manger.” You need fresh eyes to read the whole thing—again!—for errors. Every proofreading should be thorough, critical, and guided by the assumption that previous reviewers have not yet caught everything.
If your code has a table of contents, with each revision, make sure the listed page numbers correspond correctly to the sections they indicate. Double-check headers and footers on every page, including page numbers.
You should illustrate your code, but how? If you buy stock photos of people to represent your company’s upstanding corporate citizens, some readers may think the organization has been invaded by Stepford robots. If you use photos of actual employees and one of them gets fired in an embezzlement scandal six months from now, his or her image is now immortalized in the preeminent document on your company’s ethical standards. Either way, your message gets a little muddled or at least earns some snickers.
We opted for simple line icons. Whatever you choose, review graphics to make sure they can’t be misinterpreted. For example, does that single eye watching over your reporting section inspire vigilance or threaten tyranny? In one of our early drafts, an icon featured a descending line graph. Since it was illustrating a story involving a sales manager, we changed the line to an ascending one, to reflect positively on company sales.
Remember, when considering graphics and colors, that you can leverage them into branding across all ethics websites, communications, and other materials. A consistent look and feel from your office can help reinforce the message, promote your ethical culture, and make them both easily identifiable to your employee base. A third-party designer can help determine branding to best meet your goals.
Printed versus online formatting.
Sure, it’s cheaper to forego printing and simply post your code on line. However, after the obligatory reading and sign-off, online documents are easily forgotten. Besides, wouldn’t you rather read a colorful booklet that you can flip through? So would your employees. Give them something that will catch their eye from the shelf and invite them to look up how they should handle that flirtatious supervisor. Booklets are also helpful for managers who hold training sessions or review questions and case scenarios with their teams.
As a reminder, consult with works councils on code content that may impact them. Depending on your location or business, you may need CNIL approval, especially if you want to use the code for discipline. You may also need approval for your HelpLine process. In any case, make sure all your bases are covered.