Adopt, implement and promote A code of conduct

An ethical company is one which attracts foreign investors, business partners and talent, and keeps in step with international business best practices. A code of conduct must set out relevant policies and procedures which outline compliance responsibilities for all employees of the company, detail proper internal controls, auditing practices, documentation policies, and disciplinary measures. It must be tailored to the company’s specific compliance risks and challenges and provide clear guidance on how to handle key risk areas.


Based on an analysis of companies for the 2007 – 2010 period, it has been found that companies with poor anti-corruption had a 28% higher likelihood of having a scandal break in the media.

(Source: “How to Scandal-Proof Your Company”, Paul Healy in George Serafeim. Harvard Business Review, July – August 2019)

All around the world, companies with high-trust culture have better operating results.
(Source: Best Place to Work)

Recommended indicators for the second principle

Indicators proving that the principle is implemented in business operations:

  • The key compliance and integrity risk areas are addressed in the Code of Conduct, which is documented and signed. Based on this, relevant policies and procedures, which further deal with areas such as gifts and hospitality, conflict of interest and corruption, personal information, competition and consumer protection, safety and health, etc., are also adopted.
  • The Code is translated into local languages and includes a point of contact for seeking advice or reporting violations, with the non-retaliation policy explained.
  • The Code is published online and presented to all employees, contractors, suppliers…, accompanied by management address. It is regularly updated.
  • The company mandates that the entire leadership and all employees receive regular annual training in the areas covered by the Code. The training must be completed by the entire senior leadership and at least 75% of other employees (taking into account absences, other circumstances…).

Indicators proving that the leadership is making progress in implementing the principle in the company’s business practices:

  • Have adequate policies and procedures been adopted on the basis of the Code, and are they implemented?
  • What is the proportion of all employees and, in particular, leaders who have attended and concluded compliance integrity training? Have they confirmed that they understand and that they will respect the Code and related content?
  • Does the leadership promote the Code, for example, with days of corporate compliance and integrity, initiatives for activating values in practice or other similar activities?
  • How many employees have turned to compliance and integrity point of contact for advice (are the content and statistics of this consultation monitored regularly)?
  • How many internal and external corporate communications are related to values, compliance and integrity?
  • How does the company monitor and supervise compliance and integrity?