When was the last time you evaluated your company’s ethics policy?
Without an up-to-date set of protocols, employees could be confused at best and slipping bad behavior under the radar at worst. Your ethics policy helps employees make decisions that align with your company’s ethical values and standards, reducing your risk of financial or reputation damage due to a lapse.
Don’t forget to include the following important sections when writing or retooling your policy.
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1. Conflicts of Interest
No matter what industry you work in or how large your organization is, conflicts of interest (COIs) can be tricky to navigate.
For example, you don’t want to hire only family members of current employees, but should a candidate be ruled out just because they’re related to a manager? Or what if an employee has a “side hustle” where they do similar work as at your company, but for a different industry?
To ensure your company addresses conflicts of interest consistently and quickly, include a section on them in your ethics policy.
In their policy, broadcast and media company Tegna includes subsections about different types of COIs:
- Avoidance (what a conflict of interest is and how and why to avoid one)
- Appearance of impropriety
- Outside interests
- Advertising and marketing
- Confidential information
Include COI scenarios that are specific to your industry so employees don’t have to wonder what to do in any ethically confusing situation.
2. Gifts and Entertainment
Do gifts and entertainment play a large part in your business? Then they need their own section in your company’s ethics policy.
If your organization has very detailed protocols surrounding this subject, consider writing a separate policy and directing employees there for more details.
Grocery store chain Kroger does this by providing a simple three-point summary in their ethics policy, then linking to their longer, more formal gifts and entertainment policy:
“There are three important principles behind the company’s position on gifts and entertainment:
- gifts or entertainment received by associates must not influence or appear to influence decisions about how the company conducts business;
- associates may not benefit personally from company business with suppliers or others or derive personal gain from transactions made on behalf of the company;
- to the extent feasible, expenditures by suppliers should be limited, and applied to reduce the cost of goods or expenses for the ultimate benefit of our customers and shareowners.
The company’s Policy on Gifts and Entertainment provides additional guidance and procedures that associates must follow.”
3. Reporting Ethics Violations
A detailed ethics policy deters employees from committing (or help them avoid) ethical lapses. However, some might still make poor decisions, especially if they think they won’t get caught.
For this reason, every organization needs a strong reporting system in place. Managers and HR can’t catch everything, but when employees can report their concerns about their coworkers, you’ll catch unethical behavior faster and more often.
More important than having the system, though, is including information about how to use it in your ethics policy. You can’t expect employees to report if they don’t know how. In this section, list each reporting mechanism, where to find it and how to use it.
Take real estate investment trust Crown Castle’s policy for example:
“Crown Castle proactively promotes ethical behavior. Teammates should report integrity or ethical concerns, including violations or potential violations of this Policy. Teammates may report concerns through any of the following:
- A manager or supervisor
- Business Support – Employee Relations at firstname.lastname@example.org
- Any VP – Legal or the General Counsel
- Crown Castle’s Ethics Alert Line
Crown Castle’s Ethics Alert Line (“Alert Line”) is . . . the Alert Line website and Alert Line toll-free number. Alert Line works with Internal Audit, Business Support, and the Legal Department to address matters raised by alerts left on the Alert Line. The U.S. toll-free number is 866-480-6138 and is available 24 hours a day, 7 days a week. Issues can also be submitted through the Alert Line website https://crowncastle.alertline.com. Communications to the Alert Line can be submitted anonymously.”
4. Anti-Retaliation Policy
It doesn’t matter how robust and well-communicated your ethics hotline is. If employees are afraid of retaliation from the company and/or the subject of their report, they won’t speak up.
You’re asking your employees to behave ethically, so you should commit to acting ethically as a company, too. A big part of that is promising employees that they won’t be punished for raising ethical concerns and that you won’t tolerate employee-to-employee retaliation, either.
The New York Times explains their commitment to no retaliation in one succinct paragraph:
“The Company prohibits discrimination, harassment and/or retaliation against any employee who provides information or otherwise assists in an investigation or proceeding regarding any conduct that they reasonably believe to be in violation of this Policy or applicable law. If an employee engages in any such activity, the Company will not discharge, demote, suspend, threaten, harass or otherwise discriminate or retaliate against them in the terms or conditions of employment because of that activity. No officer, employee, agent, contractor or subcontractor of the Company has the authority to engage in any conduct prohibited by this paragraph.”
Your ethics policy should guide employees through sticky situations and promote your company’s ethical values. Without a strong policy in place, your company could be at risk of a damaging lapse.
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