A healthcare company was concerned that its Code of Conduct was too legalistic and difficult to read. Though employees certified each year that they were in compliance with the Code and internal surveys indicated employees were familiar with its content, management suspected that the real truth was that it was largely ignored and viewed as irrelevant. The company was concerned that since the Code was its principal communications vehicle for ethics, its ineffectiveness was marginalizing the entire ethics and compliance effort.

ELG conducted a benchmarking review assessing the company’s Code in comparison with features of other industry best-practice (and worst practice) Codes. The resulting matrix suggested specific areas for improvement. In addition, ELG conducted interviews and focus groups with select employees representing functions who had expressed concern over the Code in the past. In conjunction with management, ELG participated in employee and management teams assigned to review and suggest improvements for policy areas including conflicts and gifts.

Based on the benchmarking, focus groups and the work of the employee and management teams, ELG drafted a new Code of Conduct and provided the company with specific additional steps to improve communications and training.