Every company has a unique ethics and compliance policy. To determine the appropriate ethical guidelines for your company, you might consider studying some of the best examples of code of conduct examples for businesses. 

However, there are some common elements that should be included in every company’s ethics and compliance policy. This blog will help understand how to prepare, write and enforce your ethics and compliance policy by listing some of the key elements of a strong ethics and compliance policy.

This blog will address:

  • 7 Key elements of a strong ethics and compliance policy
  • Overview of the Process of Policy Writing
  • How to Prepare for Policy Writing
  • 3 Ways to Enforce New Policies and Procedures

7 Key Elements of a Strong Ethics and Compliance Policy

The main elements of a strong ethics and compliance policy are:

  1. Defining unethical behavior – What does your company mean by “unethical behavior”? Define terms, such as harassment, discrimination, bribery, theft, fraud and retaliation. Provide examples and consequences for violating the policy.
  2. Integrity statement – Some companies include their mission, vision and goals for employee conduct in this section of the ethics and compliance policy.
  3. Corruption – Let employees know where your company stands on the issue of corruption and workplace fraud, gifts. Some companies allow gifts to be sent or received if the gift is under a given value. Eliminate ambiguity by creating a clear rule.
  4. Reporting mechanisms- Employees are likely to uncover unethical practices in the workplace before senior executives do. Tell employees how to report misconduct. Stress the company’s open-door policy and encourage employees to use it. Include hotline phone numbers, ombudsman information and website addresses for anonymous reporting.
  5. Confidentiality – Ensuring that confidentiality will be upheld to the highest possible degree for those making complaints or involved in internal investigations can encourage employees to report, especially if they fear retaliation. Making your whistleblower hotline confidential will ensure employees feel comfortable using it. Also, workplace investigations often address very sensitive topics such as sexual harassment. Investigators and HR teams have a duty to preserve documents and/or electronically stored information (ESI) while also protecting security and anonymity. Polonious’ ISO27001 certified security ensures your evidence and case files are stored securely, while our detailed security configuration ensures you can keep employees fully anonymous, or known only to specific individuals, depending on the level of anonymity requested.
  6. Accurate accounting – Corporate accounting is highly regulated, but often violated. Include a statement directing that all transactions be accurately reflected in company books and records.
  7. Supply Chain Ethics – A Deloitte study shows that customers are increasingly expecting businesses to operate at the highest possible standards. Eliminate ambiguity by setting clear expectations for the supply chain. Companies such as Boston Consulting Group have created a Code of Conduct for Suppliers.
Ethics and Compliance

Overview of the Ethics and Compliance Policy Writing

  1. Prioritise– You can’t write every policy at once and some are more important than others, so create a list of policies that need to be done first. Prioritise your new policies and revisions in order of importance and create an order and a timeline when they each need to be completed. Meet with your policy team and decide what you need to address. Keep your end goal in mind when you’re defining these priorities, as that will help you stay on track.
  2. Conduct thorough research – Before you start writing your ethics and compliance policy, take a look at your existing procedures to zone in on how things are currently done. Our blog outlines existing policies from leading companies which will help you compare your company policies with others. You will also want to investigate any compliance issues that may have prompted your policy review.
    • Here are a few ways you can investigate or research existing processes:
      • Interview those involved in day-to-day tasks
      • Shadow coworkers to see what current procedures are
      • Interview internal and external subject matter experts
      • Find up-to-date laws, regulations, and accreditation standards
      • Identify overlapping policies to ensure consistent language and requirements.
  3. Write a draft – Writing policies or procedures is not a one-and-done effort. The initial draft of your ethics and compliance policy will require a few revisions. It makes sense to get feedback from stakeholders and coworkers, and you’ll want to revise your draft based on everything you hear back from them. Having someone other than the policy owner write the initial draft may help facilitate an outsider’s perspective, ultimately making your procedures more transferable to daily operations. This could also help simplify the language and remove technical jargon that would clutter your document. Don’t use a lot of industry-specific terms, especially as your organisation may cross several different licensing groups, functions, and even industries. The same acronyms and terms could mean different things to different employee groups, so you’ll want to avoid confusion. Limiting technical jargon will also make it easier for new hires, who may be new to the industry, to understand your policies and procedures. 
  4. Validate the procedures – To ensure your procedures make sense, you need to see them in action. It’s always a good idea to go back to the employees who do the daily work and have them perform the procedures. Remember, this only applies to the procedures portion of your manual, not the policies and prohibited actions.
  5. Send draft out for review – The key to writing a successful policy/procedure is to ensure that you receive feedback from multiple stakeholders. Continue to make revisions until your policy/procedure is thoroughly reviewed.
  6. Obtain final approval/sign off – Typically, you need someone on the executive team to sign off on each new policy. They are ultimately accountable for the policy, which means they need to officially approve the final draft. This should always be done by the highest level of leadership that makes sense for each policy. 

How to Prepare for Policy Writing

  1. Keep the end goal in mind – Consider why you’re writing your new policies, and let that inform the actual writing process. Make sure the entire team, including management, understands and buys into the “why” early on. This will set the tone, content, and even the organisation of your policy manual.
  2. Use a standard policy and procedure template – Establishing a standard policy template makes each policy document clear and organised. It sets the standard for how all policies will be written and organised, so they are easy to understand and navigate. Even if you create several new policies years later, the format will be easy to recreate because you set that standard now. This will also streamline the writing process and save a lot of time.
    • Here is an example of a template:
      • Document Header: Information about the policy including title, effective/revision dates, approver’s signature, and department.
      • Introduction/Purpose Statement: What is it about? What’s the reason for having it?
      • Policy statement: What is your organisation’s policy specific to the topic?
      • Definitions: It’s important to define terms as you go, especially for words and phrases with multiple meanings, and for industry- or job-related terms. This makes policies easy to understand and could save you from arguing about definitions should you face litigation.
      • Procedures: Step-by-step instructions for routine tasks and operations. Ask the people who actually perform these tasks for help in writing the steps.
      • Conduct: Guidelines for proper behavior and restrictions on employee behavior. What are the consequences of a violation?
      • Reporting requirements: How do employees report an incident or violation? What’s the procedure for reporting?
  3. Utilise the right tools to manage the process – You could always write all the policies in your word processor of choice, but then you have to share the document so everyone can mark up their own version, and then you’ve got several versions of the same document to wade through. Or you could upload it to a cloud word processor, like Google Docs, which at least reduces the number of different versions you’re juggling. Everyone can edit the same document and all the changes will be held in the same document. But you still need something that gives you version control and can map your policies to your accreditation and licensing requirements. So it pays to use online policy management software in order to write your new policies. It makes everything visible and transparent, and you can even automate the approval process by your managers.
  4. Form a policy management team – Since your policies will affect everyone across the organisation, bring in people from different departments to help. Tap into the subject matter experts in how a particular department or role functions. Include the people who understand and can help you adhere to any local, state, and federal laws that affect how everyone functions.

How Polonious can Help

Even the strongest ethics and compliance policy won’t make a difference, if it isn’t properly enforced. Once the policy is created, it must be reinforced through training, repetition and enforcement of consequences for violating it. Most importantly, company executives need to set the tone from the top, demonstrating ethical business practices and attitudes and a zero-tolerance policy for violations.

Polonious can help support your business by securing important documents such as policies and investigation reports while protecting anonymity. Implementing the Polonious Case Management System can also help you improve communication throughout the supply chain enabling stronger adherence to better internal management processes.