Code of Conduct

What an employee code of conduct covers

Codes vary by industry, but most include:

• Respect and non-discrimination: no harassment, bullying or discrimination; links to the full anti-harassment policy.
• Honesty and integrity: accurate records, timecards, expense reports and customer information.
• Conflicts of interest: outside jobs, relationships with vendors, family members in the reporting line.
• Gifts and entertainment: limits and disclosure.
• Anti-bribery and corruption, especially for organizations working internationally.
• Confidential information and data privacy: customer data, trade secrets, personnel records.
• Use of company assets: equipment, systems, time.
• Safety and substance use.
• Social media and public statements on behalf of the organization.
• Speak-up and non-retaliation: how to report concerns, including anonymously, and a clear statement that retaliation is prohibited.
• Consequences: that violations can lead to discipline up to termination.

Our code of conduct template includes each section with sample wording you can adapt.

Code of conduct vs code of ethics vs HR policies

A code of ethics states principles and values, usually short and aspirational: "We act with integrity." A code of conduct turns those principles into specific behavior: "Do not accept gifts worth more than $75 from a vendor; disclose any gift." Many organizations combine them into one document called a code of business conduct.

HR policies go into operating detail on specific topics such as leave, attendance and overtime. The code sits above them and points to them. All three usually live in or alongside the employee handbook.

Why organizations have one

Part of it is legal and regulatory. Under the Sarbanes-Oxley Act, US public companies must disclose whether they have adopted a code of ethics for senior financial officers, and NYSE and Nasdaq listing rules require listed companies to adopt a code of conduct covering directors, officers and employees. Federal contractors on larger contracts must have a written code of business ethics under the Federal Acquisition Regulation. The US Sentencing Guidelines treat an effective compliance and ethics program, including written standards, as a factor in how organizations are sentenced for violations.

The practical reason matters as much: a clear code lets managers make consistent decisions and gives employees a reference point when a situation is ambiguous.

Making it usable for frontline employees

Many codes are written by lawyers for lawyers and run 40 pages. A warehouse associate or contact center agent will never read that. Practical fixes:

• Write at a plain reading level, in short sections.
• Use realistic scenarios from your own operations: "A customer offers you a $50 gift card for fixing their account quickly. What do you do?"
• Translate it into the languages your workforce reads.
• Put a one-page summary on the break room wall and in the onboarding packet.
• Make the reporting channel visible: hotline number, web form, HR contact.

Cover it in onboarding and in annual compliance training, with short scenario quizzes rather than a slide deck.

Enforcement and fairness

A code is only credible if it's applied the same way to a top salesperson and a new hire. Inconsistent enforcement is one of the most common facts in discrimination and retaliation claims. Route alleged violations through a defined process, investigate serious ones, document decisions and track outcomes by department and demographic group.

Collect a signed or electronic acknowledgment when employees join and whenever the code changes materially. Under the National Labor Relations Act, rules on confidentiality, civility and social media should not be so broad that they discourage employees from discussing pay or working conditions, so have counsel review those sections. Rules differ by country; EU whistleblower rules, for example, require certain organizations to maintain internal reporting channels.

Common mistakes

• Copying another company's code without adapting it to your risks.
• No examples, so employees can't tell where the line is.
• No reporting channel, or one that goes to the person being reported.
• Never updating it for remote work, AI tools or social media.
• Leadership exemptions, written or unwritten.