What We Can Learn from The Coca-Cola Company’s Code of Conduct

Be clear, direct and detailed

Posted by Dawn Lomer in Code of Conduct, Ethics & Compliance, Human Resources on October 24th, 2013

The Coca-Cola Company’s code of conduct has been held up as an example of what a company’s code of conduct should look like. It’s a 44-page document, publicly available, that addresses every aspect of how the company expects employees to behave.

Some may feel it is too detailed, and it certainly may be seen as too long. But a code of conduct that provides clear direction and examples of different situations employees may encounter with instructions on how to handle them, is sure to get the message across. The company’s code is so clearly written that it leaves no room for misinterpretation.

Instead of abstract ideas about what it means to act ethically, the code of conduct contains clear and simple language.
One of the most useful sections of The Coca-Cola Company’s code of conduct is the section outlining what’s expected of managers. Instead of abstract ideas about what it means to act ethically, the code of conduct contains clear and simple language. Direct instructions are provided, absent the flowery rhetoric that can sometimes creep into ethics-related documentation.

Culture of Ethics

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Managers are instructed to promote a culture of ethics and compliance and to “model appropriate conduct” at all times. By asking managers to “model” behavior, The Coca-Cola Company reinforces the message that employees watch their managers and see their behavior as an example of what is expected.

The code breaks down the promotion of ethics into bullet points that translate directly into action, as follows:

  • Ensure that the people you supervise understand their responsibilities under the Code and other Company policies.
  • Make opportunities to discuss the Code and reinforce the importance of ethics and compliance with employees.
  • Create an environment where employees feel comfortable raising concerns without fear of retaliation.
  • Consider conduct in relation to the Code and other Company policies when evaluating employees.
  • Never encourage or direct employees to achieve business results at the expense of ethical conduct or compliance with the Code or the law.
  • Always act to stop violations of the Code or the law by those you supervise.

The language used in this section leaves little no for interpretation or misunderstanding. If an employee who has high sales but uses questionable tactics receives a good evaluation from his or her manager, there is no room to argue that the manager felt that the employee’s results warranted the evaluation.

Encouraging Internal Reporting

Another section of the code explains how managers should address questions and concerns. This is an important part of any compliance program as it encourages employees to speak up when they see something wrong, so that the company can respond with an internal investigation. A speak-up culture can save a company from disaster, huge fines and even criminal liability. So it makes sense to have this spelled out clearly in a code of conduct.

“If approached with a question or concern related to the Code, listen carefully and give the employee your complete attention. Ask for clarification and additional information. Answer any questions if you can, but do not feel that you must give an immediate response. Seek help if you need it. If an employee raises a concern that may require investigation under the Code, contact your Local Ethics Officer, Company legal counsel, senior finance personnel or the Ethics & Compliance Office.”

These instructions tell managers exactly what to do when faced with evidence of an ethics violation. When everyone knows what’s expected of them it’s more likely they will do what’s expected of them.


Dawn Lomer
Dawn Lomer

Managing Editor

Dawn Lomer is the managing editor at i-Sight Software and a Certified Fraud Examiner (CFE). She writes about topics related to workplace investigations, ethics and compliance, data security and e-discovery, and hosts i-Sight webinars.