Risk & Compliance

Following the Code

These days, every company has devised a formal code of conduct. Getting employees to read and follow it is another challenge altogether.
Esther SheinMarch 31, 2006

When it comes to making sure the corporate code of conduct is followed, executives at Textron Inc. rely on good old-fashioned trust — sprinkled with some checks and balances and formal feedback tools such as surveys and focus groups.

Having a corporate code of conduct in place these days is a given, but making sure employees are following it is often the bigger challenge.

“This is really a matter of leaders being tuned in to those whom they lead,” says Bill Clegg, executive director of ethics and compliance at Textron. For example, he says, a sales manager might accompany a salesperson on calls from time to time and assess behaviors. The company’s conduct code was established in the late 1970s.

“Ultimately, however, following a given policy comes back to values,” Clegg says. “What do any of us do when the boss, or our mothers, fathers, etc. are not watching? Trust and personal responsibility are key to any successful policy.”

At Dow Corning, all corporate policies are posted on a dedicated link on the company intranet, which also holds its code of business conduct. Articles are published frequently on the intranet to “draw employees’ attention to the policy page and to remind all employees that compliance with the policies is a condition of employment,” says company spokesman Jarrod Erpelding, adding that managers are required to discuss those policies with their teams.

Erpelding acknowledges it is “difficult to monitor” whether the policies are actually being adhered to. For that reason, Dow Corning employs a “balance of consequences” concept. That means if an employee is “caught” doing something the “right way,” managers are encouraged to acknowledge that behavior, and they are taught to emphasize positive behavior more than negative.

“These are especially true for behaviors that involve safety issues,” says Erpelding. “In many of these cases, it’s easier and more effective to reward positive behavior.” While in some areas there are obvious controls in place where the company can monitor things like credit card, cell phone and computer usage, “from time to time…the company has used these to discipline violators. Proper controls and well-trained managers help manage these situations appropriately — and Dow Corning has very few issues in these areas.”