“A company’s code of conduct is often the foundation upon which an effective compliance program is built.”~ A Resource Guide to the U.S. Foreign Corrupt Practices Act

THEN GENESIS OF A WRITTEN CODE

TALE OF TWO CODESPAST & CURRENT BEST PRACTICES

USER-FRIENDLY CODES THAT HELP MITIGATE RELEVANT RISKS

Tone from the Top

Readability & Tone

Reporting & Non-Retaliation

Values Statements &Stakeholder Commitment

All Relevant RiskTopics Coverage

Learning Aids

Accessibility:Internally and Externally

Presentation. Style. Organization.

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Collection/summaries of corporate policies

Legalese, unapproachable content

Impersonal messaging and tone

Overly general coverage of risk topics

MEETING REQUIREMENTSEmployees should strive to avoid even the appearance of a conflict of interest by avoiding associations or investment interests that interfere, might interfere or might appear to interfere with the independent exercise of judgement in [Redacted] best interests.

NOW CULTURAL AWAKENING

INCREASING EMPLOYEE ENGAGEMENT LEADS TO BETTER RESULTS IN A

COMPLIANCE PROGRAM

9 sec.Average Attention Span of a GoldfishAverage Attention Span in 2013

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