Compliance Week 2022: How to create a values-based code of conduct

Having an up-to-date, visually engaging, readable, and usable code of conduct is fundamental to having an effective ethics and compliance program. But what’s next? How do you get employees to go back to the code often and use it as a tool to help them do the right thing? How do you take the principles and behaviors outlined in the code and embed them in the way all your employees behave on a daily basis—including frontline workers, middle managers, and senior leaders?

These were the questions explored during LRN’s panel discussion at the 2022 Compliance Week National Conference earlier this month. The panel, “A tale of two companies: The journey to a values-based code of conduct,” was moderated by LRN’s Senior E&C Advisor and resident code expert Jim Walton and featured the following compliance experts: 

  • Cheryl Curbeam: Chief Risk & Compliance Officer at Corteva Agriscience 
  • Carlos Villagrán Muñoz: Director of Compliance at CMPC 

Panelists shared how they used technology, ongoing communications, and meaningful conversations to make their codes of conduct work in the real world. While each company is unique in its code of conduct journey—with different cultures, practices, and risk areas—the group shared best practices that they believed were universal for any code reinvention process. Here are some key insights from the discussion. 

How CMPC refreshed its code of conduct to reflect transparency 

Both panelists talked about the challenges and opportunities they faced with their codes of conduct, as well as what they did to transform their codes. 

Villagrán described how CMPC reinvented their code at a crucial time when they were re-evaluating their culture as a whole. An anti-trust crisis had recently affected the company and its consumers directly. From entry-level employees to the top of the organization and its board of directors, people were generally afraid to report any misconduct or speak up. Villagrán and his team determined there were three key pillars to address from this crisis: cultivating a culture of transparency, enhancing training and leadership modeling, and shifting the mindset from rules to values. 

CMPC’s ethics and compliance team began by explicitly stating the dos and don’ts in their code of conduct, so it was clear to all team members what the organization’s position was on all policies and avoided any gray areas. Then, they developed specific compliance training for leaders so that they would be better equipped to listen to and follow-through on employee concerns of misconduct. CMPC also began to shift the way they held internal meetings and daily business, opening forums up so that anyone from the company could voice their opinions.  

As time went on and their program matured, CMPC began to incorporate their open, transparent mindset into their code using more values-based messaging. They were able to rebuild and move forward from their past crisis. Today, the company’s speak-up culture and refreshed code have helped increase reports of possible misconduct, as more people feel empowered to use their voice.  

How Corteva created a code of conduct that unified its culture 

For Curbeam, transforming Corteva’s code of conduct was also an exercise in creating a new culture. After successfully merging with Dow DuPont, Corteva Agriscience spun off to become its own agriculture-based company with departments from DuPont, Dow, and Pioneer Seeds. Ahead of its market debut, the company—and its new E&C program—wanted to build a culture that respected the history of each entity while still creating its own unique footprint. But how do you effectively communicate who you are and how you do the right thing when you are just starting out? 

Curbeam and her team agreed that being proactive in developing the new company code—in addition to building out the full ethics and compliance program—would help unite Corteva under one brand identity and set of values. Because Corteva was global, they also wanted to make sure their code reached a broader audience and was universal in language and tone. They held focus groups with team members of all levels from around the world, asking them to share ideas on what should be included in the code: from imagery to formatting to messaging. The conversations revealed two key themes:  

  • The code should emphasize the importance of doing the right thing, rather than simply telling people what to do. 
  • The code should be easy to use, read, and refer to when making decisions. 

When Corteva launched as an organization, so did its entire ethics and compliance program—including the code of conduct. As part of the process, Corteva developed an E&C mobile app to house the code (as well as policies, hotline, training, and other key program components) so employees could easily access the information they needed. The company has since reached 100% compliance for code of conduct training and certifications. 

4 best practices for effective code of conduct design  

Despite having different company objectives, each panelist believed that the following best practices were universal for effective code of conduct reinvention. 

  • Keep it simple. Codes do not need to be complicated. Using clear, concise language to explain policies, procedures, and other E&C information will make it easier to understand and remember. 
  • Make it accessible. It’s important that your code of conduct can reach all your audiences. Research shows that web-based codes and microsites are now starting to replace the typical digital PDF because of how navigable and searchable they are. But it is worth noting that having your code in a variety of formats—including a paper copy, digital PDF, online, or in a mobile app—can help ensure
  • Keep it relatable. Employees will have a better understanding of your code if they can see how it works in practice. Consider sharing case studies and situational examples that your organization faces every day to help illustrate different code components. 
  • Make it your own. Every company is different and unique, especially when it comes to culture and values. So, it makes sense that your code of conduct should reflect that. Consider the tone of the language you use—whether you focus on rules, regulations, values, or culture—and how you present information to readers. Utilizing your company brand guidelines can also help your code look and feel more integrated with your wider E&C program. 

The key takeaway 

A code of conduct is your organization’s character and culture written down. While the best practices discussed during the panel are important for any organization, Villagrán and Curbeam agreed that reflecting your unique values and culture dynamics was essential to making your code of conduct useful and real to your day-to-day business.  

You can learn more about writing or refreshing your code of conduct here under the E&C Insights section of