Code of Business Conduct Template (Corporate Ethics Code)

Corporate ethics code: leadership message, decision test, speak-up channels, bribery, gifts, conflicts, competition, sanctions, records, waivers, training

ISO और अनुपालनमानकISO 37301:2021 cl. 5.2; ISO 37001:2025 cl. 5.2 (cited only)code business conductअपडेट किया गया 29 अक्टू॰ 2026

एडिटर में खोलें.md डाउनलोड करें

उपयोग कैसे करें: Use it to publish or refresh an employee-facing ethics code that points to your detailed policies. Fill the leadership message, speak-up channels and gift thresholds first, and test the draft with employees. The main pitfall is a long legalistic code that repeats every policy and that nobody reads.

प्रीव्यू

Code of Business Conduct: [Organization name]

A code of business conduct sets out the ethical standards that every director, employee and representative of an organisation must follow, how to make decisions when the rules are unclear, and how to raise a concern without fear of retaliation. Its structure is aligned with ISO 37301:2021 (compliance management systems, with Amd 1:2024), clause 5.2 on the compliance policy, and links to the anti-bribery policy required by ISO 37001:2025 clause 5.2. It also covers the elements of a code of ethics listed in US SEC Regulation S-K Item 406. It is a corporate ethics code: for an open-source or event community code of conduct, use dev/code-of-conduct. Replace every [bracketed] value and every row marked Example. This is a documentation format, not legal advice: check the current official text and ask a qualified professional.

A message from leadership
Who this code applies to and how to use it
Speaking up
Respect for people
Integrity in business
Information and assets
Communities and the wider world
Breaches, waivers and discipline
Governance, training and attestation
Legal context examples
References

Document control

Field	Value
Document ID	[POL-ETH-001]
Version	[1.0]
Status	[Draft / In review / Approved]
Owner	[Chief compliance officer, @name]
Approved by	[Board of directors, YYYY-MM-DD]
Approvers/reviewers	[Legal, HR, internal audit]
Effective date	YYYY-MM-DD
Last updated	YYYY-MM-DD
Next review	YYYY-MM-DD (at least every [two] years)
Classification	[Public]
Languages	[List; the [English] version prevails]

Approvals

Role	Name	Decision	Date
Board of directors	[@chair]	[Approved]	YYYY-MM-DD
Chief compliance officer	[@name]	[Recommended]	YYYY-MM-DD

Revision history

Version	Date	Author	Change summary
0.1	YYYY-MM-DD	[@name]	First draft after employee focus groups
1.0	YYYY-MM-DD	[@name]	Example: Approved by the board, fraud prevention section added

1. A message from leadership

[Two or three paragraphs signed by the chief executive or chair.]

Example: "Our customers trust our bridges, pumps and turbines with their safety. That trust depends on every test report being honest and every contract being won fairly. If something feels wrong, tell us. You will never be penalised for raising a concern in good faith."

2. Who this code applies to and how to use it

This code applies to [all directors, officers, employees, temporary staff and contractors of the group]. We expect [agents, distributors, joint venture partners and suppliers] to follow equivalent standards, set in the supplier code and contracts.

When a situation is not covered, ask:

Question	If the answer is no or unsure
Is it legal and consistent with our policies?	Stop and ask [compliance]
Would I be comfortable if it were reported in the news?	Stop and ask
Would it hold up if my manager or a regulator reviewed it?	Stop and ask
Is it fair to customers, colleagues and the public?	Stop and ask

3. Speaking up

Channel	Details
Your manager or HR	[Contacts]
Compliance team	[Email, phone]
Independent hotline (anonymous option)	[Phone, web address, languages]
External authority	[Where law provides, for example under the EU Whistleblowing Directive (EU) 2019/1937]

We do not tolerate retaliation against anyone who raises a concern in good faith or helps an investigation. Retaliation is itself a breach of this code. Details: compliance/whistleblowing-policy.

4. Respect for people

Topic	Our standard	Policy
Equal treatment	We hire, pay and promote on merit, without discrimination	[HR-POL-nn]
Harassment and bullying	We do not accept harassment of any kind, online or offline	[HR-POL-nn]
Health and safety	Anyone may stop work they believe is unsafe	[HSE-POL-nn]
Human rights and fair labour	No forced or child labour in our operations or supply chain	[Supplier code]

5. Integrity in business

5.1 Bribery and corruption

We do not offer, give, request or accept bribes, including facilitation payments, directly or through anyone acting for us. Full rules, due diligence and red flags: compliance/iso-37001-anti-bribery.

5.2 Gifts and hospitality

Rule	Value
Never acceptable	Cash or cash equivalents, anything during a tender, anything to a public official without approval
Allowed without approval	Example: Modest items up to [EUR 50] per occasion
Needs approval and registration	Example: Above [EUR 50] per occasion or [EUR 150] per counterparty per year
Register	[Link to gifts and hospitality register]

5.3 Conflicts of interest

Declare any personal, financial or family interest that could influence or appear to influence your work, when it arises and at the yearly attestation. Register: compliance/conflicts-of-interest-register.

5.4 Fair competition

We compete on merit. We do not agree prices, bids, markets or customers with competitors, and we leave any meeting where such topics come up.

5.5 Trade controls and sanctions

We screen customers, suppliers and shipments and follow the export control and sanctions laws that apply. Procedure: compliance/sanctions-compliance-procedure.

5.6 Fraud and money laundering

We do not falsify records, misstate results or help anyone commit fraud or launder money. Report suspicions through the channels in section 3.

6. Information and assets

Topic	Our standard	Policy
Accurate records and reporting	Books, test reports and disclosures are complete, accurate and timely	[FIN-POL-nn]
Confidential information	Use it only for its purpose and protect it after you leave	`compliance/information-security-policy`
Personal data	Collect and use it only as our privacy policies allow	`legal-lite/privacy-policy`
Inside information	Do not trade on or pass on inside information about us or others	[Insider dealing policy]
Company assets and AI tools	Use them for legitimate business; follow the acceptable use rules	`compliance/acceptable-use-policy`

7. Communities and the wider world

Topic	Our standard
Political activity	No company political donations [unless approved by the board and lawful]; personal activity in your own time and name
Charitable donations and sponsorship	Approved, recorded and never linked to a business decision
Environment	We meet our environmental permits and report honestly on our impact
Media and social media	Only authorised spokespeople speak for the company

8. Breaches, waivers and discipline

Breaches can lead to disciplinary action up to dismissal and may be reported to authorities. Investigations are fair, confidential and proportionate. Only [the board or its audit committee] may grant a waiver for a director or executive officer; waivers are recorded and disclosed where law or listing rules require.

9. Governance, training and attestation

Role	Responsibility
Board or audit committee	Approves the code, oversees compliance, receives reports
Chief compliance officer	Owns the code, advice, training, reporting
Managers	Lead by example, respond to concerns, prevent retaliation
Everyone	Read, follow, complete training, attest yearly, speak up

Metric	Value
Staff in scope (Example)	1,240
Training and attestation complete (Example)	1,178 (95.0%)
Outstanding, escalated to managers (Example)	62

10. Legal context examples

As of October 2026 (not legal advice; check the current official text):

Jurisdiction	Point	Official source
EU	Directive (EU) 2019/1937 protects people who report breaches of EU law and requires internal reporting channels for many employers	https://eur-lex.europa.eu/eli/dir/2019/1937/oj
UK	Bribery Act 2010 section 7 (failure to prevent bribery, adequate procedures defence). The failure to prevent fraud offence in the Economic Crime and Corporate Transparency Act 2023 applies to large organisations from 1 September 2025, with a reasonable procedures defence	https://www.gov.uk/government/publications/offence-of-failure-to-prevent-fraud-introduced-by-eccta
US	SEC Regulation S-K Item 406 (17 CFR 229.406) asks registrants to disclose whether they have a code of ethics for senior executive and financial officers. The DOJ Evaluation of Corporate Compliance Programs (updated September 2024) asks how the code is communicated and enforced	https://www.justice.gov/criminal/criminal-fraud/page/file/937501/dl

11. References

Reference	Edition	Use
ISO 37301, Compliance management systems, Requirements with guidance for use	2021, with Amd 1:2024	Clause 5.2 compliance policy, culture and governance
ISO 37001, Anti-bribery management systems, Requirements with guidance for use	2025 (second edition)	Clause 5.2 anti-bribery policy
ISO 37002, Whistleblowing management systems	2021	Speaking up section
SEC Regulation S-K Item 406	Current eCFR	Code of ethics elements
DOJ Evaluation of Corporate Compliance Programs	September 2024	Effectiveness questions

Standard and licence note

Structure aligned with ISO 37301:2021, Compliance management systems, Requirements with guidance for use (with Amd 1:2024), and ISO 37001:2025, Anti-bribery management systems, Requirements with guidance for use. Only names, editions and clause numbers are cited; the code text, decision test, tables and guidance are original text written for this collection and reproduce no wording from the standards. The legal examples are dated summaries and the worked example is fictional. Check the current editions and laws before use. This is a documentation format, not legal advice.

Official text: ISO, purchase or licensed access: https://www.iso.org/standard/75080.html (ISO 37301) and https://www.iso.org/standard/85816.html (ISO 37001), also available from national standards bodies.

Template licence: MIT.