1. Introduction:
– Statement by the CEO/President of his commitment to the code, and a promise to act consistently with it
– Explanation of why the code is being promulgated, to whom it applies, and how it is to be used
– Statement that legality is necessary but often an insufficient standard of ethical conduct

2. Core values/cultural philosophy:
– Organization’s vision or mission statement
– Guiding “moral/ethical” principles such as honesty, respect, fairness
– And “pragmatic/organizational” principles such as excellence, quality, customer satisfaction, sustainable development

3. Elements of the code:
– See ‘Elements of an Ethics Code’
– Specific policies expanding element headings (such as conflicts of interest, records keeping, antitrust, insider trading, discrimination/harassment, health/safety, environmental)
– References to applicable professional ethics codes
– Behavioral examples of the very types of dilemmas that an employee might encounter
– A statement that such illustrations are not intended to be inclusive or limiting

4. Supporting infrastructure:
– Where to find more information or go for interpretation (such as an immediate supervisor, ethics office, or legal counsel)
– Reporting violations via the Ethics Hotline
– Statement on the organization’s commitment to confidentiality and non-retaliation for the use of any of the supporting systems

5. Personal responsibility:
– A statement that it is each individual’s responsibility to know and understand the requirements and expectations set forth in the code and to meet those standards
– A statement that employees must report suspected violations of the code, and that failure to do so is itself a violation
– Affirm the potential for disciplinary consequences including dismissal as well as legal action (resulting in civil or criminal penalties) for code violations
– Acknowledgment form
– A statement that failure to read the code or sign the acknowledgment form does not excuse an employee from the standards