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Activate Your Code of Conduct Through Interactive Learning


March 30, 2020  |  Laraine McKinnon


People often think of the Code of Conduct a flat set of rules and requirements. They get rolled out once a year, covering everything from company values to policies around cybersecurity, privacy, gifts, and harassment. Everyone reads them (or at least says they do), signs off and you’re done for another year.

But are you missing the point?

  • While you’re asking for the attention of each employee are you making the best use of their time?
  • Are employees getting a true understanding of your mission, values and why following key rules is important to the success of your organization?
  • Are employees aligned and incented to create a culture of compliance?
  • Do employees understand what behaviors create a healthy and respectful workplace culture?

A better way to do a Code of Conduct annual review 

What if instead of an annual check-the-box Code of Conduct PDF review, you could provoke learners to think about your Mission, Values, and Code of Conduct and the role they play in their work lives? We propose that the annual Code of Conduct review become an interactive exercise—a way to build and reinforce workplace culture—by highlighting those key behaviors and skills that help people work better together in an ethical way. We think it’s a prime opportunity to focus the workforce on building trust amongst colleagues, making clear decisions, holding each other accountable, and connecting to create “the way things should work” at work.

Our interactive training brings our clients’ learners through a narrative of your organization’s mission and values, the behaviors you want to see at your organization to maximize trust and accountability, and the key topics you’re addressing in your Code. We help employees internalize expectations set by the rules around cybersecurity, privacy, anti-bribery and insider trading in a way that makes “the right thing to do” much more intuitive. 

We ask learners for their opinions and insights on trust and accountability:

  • Do people you work with allow their emotions to influence their decisions? 
  • Do your colleagues take chances or stay safely “in the box”? 
  • Does your organization do deals that are inconsistent with your values? 
  • Is it okay for you to tell your supervisor that you disagree with them? 
  • Are people comfortable sharing mistakes so others can learn from them?

As well as key learnings:

  • Is it okay to give my equipment and passwords to a trusted co-worker? (cybersecurity)
  • Can your personal social media activity create problems for you at work? (social media)
  • Could buying stock in a vendor’s company violate insider trading laws? (insider trading)
  • Could doing some consulting work create a conflict of interest (conflicts of interest)
  • Is it okay to collect email addresses for clients of your global offices for an event you’re sponsoring? (privacy)
  • Is my chat with my co-worker private or can the company access the chat log? (privacy)

Those Challenging Topics

Another aspect of our approach is delving into challenging topics that come up every day. In our online Code of Conduct training, we cover the day to day decisions: the employee taking one 6am call a month so she can expense her home internet, or the salesperson going to an unnecessary conference so she can spend the weekend in Vancouver. And we don’t shy away from the bigger stuff, those decisions that can change the course of the future: should our company take a big revenue deal that isn’t aligned with our values? We help employees think through these issues before they happen and ask them their opinions. Would you have given feedback to the colleague with questionable expenses? Would most people in your organization still go to the conference? What stops your colleagues from making clear decisions? How often do you think we’d have gotten better results if people had paused before making a decision? Through this social polling and peer learning, we help the employee understand their organizational norms, and we provide aggregated anonymized insights (and red flags) to company leaders too.

Culture of Compliance

The US Department of Justice’s criminal division has an online evaluation of corporate compliance programs. It says: “Beyond compliance structures, policies, and procedures, it is important for a company to create and foster a culture of ethics and compliance with the law. The effectiveness of a compliance program requires a high-level commitment by company leadership to implement a culture of compliance from the top.” 

That’s why many of our clients have their CEO, Chief Compliance Officer, and other key leaders create a video message to kick off their Code of Conduct training and take an interactive experiential approach like ours.

Some of our clients like to think of the annual Code of Conduct exercise as a Code of Culture. They focus on creating strong positive norms, where interactions between colleagues are positive and productive, where inevitable conflict becomes more constructive, where different points of view are celebrated, and where everyone recognizes they are in the boat together and need to row in the same direction. Focusing on workplace behaviors is a seamless way to incorporate your company values. (In fact, one of our values at Emtrain is “rowing in the same direction.”)

Maybe Code of Conduct is Not Annual

While it’s practical to do an annual Code of Conduct campaign to ensure and track annual completion, we’re also interested in providing short bursts of learning throughout the year. We break all of our content down into two to four-minute microlessons. They can be used to keep people fresh on what’s important or teach where there are deficiencies.

How Can We Help Promote Your Code of Conduct?

We’re encouraged by whatever you do to promote the key tenets of your Code of Conduct, help your employees develop an intuition for what’s right and wrong, and create a culture of compliance, trust, and accountability so it becomes the organizational norm: just “‘he way things work around here.” If our approach sounds useful, please reach out.

See how we introduce our Code of Conduct course in our latest video and request a demo of our Code of Conduct course to learn more. 


code of conductelearning

Laraine McKinnon

Laraine is an advisor to Emtrain, and an unconscious bias expert. Laraine is a passionate supporter of diversity in the workplace; she focuses on blending behavioral science (managing unconscious bias, organizational behavior), big data and practical implementations to transform workplace cultures. Laraine has led high-performance customer success and sales teams at BlackRock and Barclays Global Investors, and founded strategic consulting firm LMC17.



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