July 7, 2022

In the last of our 3-part blog series with Scott Schneider, Traliant’s Head of Content Development, we learn how often a code of conduct should be revisited with leadership and employees and how to bring it to life through ongoing training and discussion. This interview originally aired on Tom Fox’s FCPA Compliance Report podcast and has been edited for length and clarity.

Keeping Your Code Current and Top of Mind

Tom: Codes that are interactive with hyperlinks put additional resources at the fingertips of employees. How should a company think about the resources it provides in a code of conduct?

Scott: If you’re trying to drive people to your code, and you want to make good on the promise that it will help you make good decisions, then it must be more than a statement that says, “We don’t bribe” or “We don’t launder money.”  You want to empower employees by giving them resources to make good decisions and you need to give them the assurance that you have people who can help them with hard issues.

Tom: When should companies revisit their code?

Scott: Your code is the highest-level description of how you operate. It’s probably not going to change dramatically year to year, but it’s important to look at it annually. This sends a strong message to everybody that the code is important and you want to be sure that it still speaks to the issues it needs to. I wouldn’t want to go in front of any stakeholder, let alone a regulatory body, and explain that we looked at our code two years ago and will review it again in another two years.

Tom: How often should employees receive code of conduct training?

Scott: I’m in the compliance training industry, so I admit my bias. I think employees should be trained every year, but I also think we need to define training more broadly. Whether it’s a traditional training course, bite-size pieces or reminders, training elevates code visibility so people understand it matters. Training also empowers managers by giving them topics they can talk to their teams about in weekly meetings. And the code and training can also be addressed by the CEO or other leaders in their messages to employees.

Tom: Do you see the code of conduct and training continuing to be the backbone of organizational culture and compliance?

Scott: There will be no shortage of scandals and missteps. So, I don’t see any incentives for leaders to say, “Okay, we’re going to relieve companies of the burden of articulating how they conduct business and what they stand for.” 

That means codes are here to stay, but I think they’ll evolve and we’ll judge them in different ways. Instead of sitting at the top of a pedestal or on a bookshelf, codes will become more practical. So, they’ll continue to answer big questions like, “What do we stand for?” but they’ll also answer questions like “Why should I, as an employee, engage with the code in my own work life?”

To listen to the entire FCPA Compliance Report interview with Scott Schneider, go to https://bit.ly/3MYZqyE.

Read Part 1 and Part 2.

Scott Schneider, Traliant’s Head of Content, is a compliance professional and former attorney. He leverages more than two decades of compliance experience to create impactful training solutions that help employees explore and understand critical compliance and work issues.