1. The value of a strong code of conduct
Amman, 16th October 2017
Kristien Verbraeken, Integrity officer, Government of Flanders

2. Is it useful to have code of conduct?
Code of conduct is:
often most tangible tool of integrity policy in organisation
a common set of guidelines for do’s and don’ts for behaviour of employees in organisation
‘contract’ with society: it describes what organisation stands for and for what it can be held accountable –> transparency
often considered as combination of
Values and norms for good, ethical behaviour
Concrete behavioural guidelines consistent with these values and norms
Goals of code of conduct:
prevention by stimulting ethical behaviour and as such preventing unethical behaviour
control because when the rules of code are not complied with sanctions can be applied

3. Functions of code of conduct
Clarity on what is considered ethical behaviour in organisation: it offers guidance for employees to work in an ethical way. Depending on level of support and belief in it, it will stimulate the aimed for behaviour
! Not all behaviour and situations can be or need to be set down and managed in organsation: personal judgement of employees must be continually stimulated e.g. by dilemma training, moral judgement, open debate and feedback culture
To be able to identify/explicitate and name ethical and unethical behaviour
When based on topics that are vivid in organisation, it can create dialogue on values, rules, dilemmas. It stimulates ethical awareness in organisation (staff and management)

4. Functions of code of conduct
Help with dilemmas:
code explicitates values and draws attention to values: leads to insights that are useful when weighing values and interests in dilemmas. With trainings employees can learn how to analyse dilemmas and steps they have to take to reach good, ethical decision. Knowledge of code of conduct can be important help.
Raise acccountability
Code of conduct makes it possible to hold employees accountable for actions and behaviour, both by organisation and society. On condition: code is known and staff is familiar with content by training, communication …
Stimulate engagement and loyality
By explicitating values and norms of organisation, employees can identify with them which raises engagement and loyality to strive for goals and values of organisation

5. Type of code of conduct? Preliminary decisions
Binding code?
Organisation can make code of conduct binding: non compliance can lead to sanction or can be used in appraisal and performance interviews. + : clarity and code will be taken seriously - : risk focus on rules and avoidance violations (less attention to personal ethical judgement) but can be avoided by stimulating measures e. g. dilemma training, case analyses…
Concise or detailed code?
General concise code can be applicable to all employees. A made to measure detailed code can be tuned to real-life situations of specific groups, entities, levels.
! : detailed code can give impression that everything that is not described in code, is permissable.

6. Type of code of conduct? Preliminary decisions
New organisation code of conduct or blueprint example other organisation?
As employees have to put code of conduct into daily practice, code has to be authentic and in keeping with the reality of organisation. Therefore: copy pasting code of conduct of other organisation is not good practice. Code of conduct of other organisations can offer inspiration as long as it is adapted to the culture, structure and practices of own organisation.
To enhance compliance: important to involve employees in creating or renewing code of conduct

7. Specific codes of conduct?
When specific groups (vulnerable functions) or entities need more detailed code to tackle specific work situations, these specific codes have:
to be in keeping with the general code of conduct
should not repeat the general code to avoid any confusion or unclarity
can never be more lenient than the general code of conduct.
Certain specific topics might also benefit from specific code of conduct e.g. Government of Flanders has specific code on ethical use of ICT
Code of conduct should be linked with other strategic documents such as value charter, mission statement and goals and vision of organisation.

8. How to make strong code of conduct? From paper to practice
3 big steps
Practical and content preparation
Implementation
Follow-up
Practical preparation
Get support and go-ahead of management for making code of conduct
Gathering of project group with project leader, appointed by management: project group consists of representatives of different entities of organisation, with different relevant functions (HR, legal, internal control, ethics…) and with good knowledge of the organisation

9. Preparation of content
Project group:
Gathers notions and dilemmas on ethics that are present in organisation
Analyses current rules and guidelines to check what is already in place and what is still missing
When the analysis shows that current rules and regulations are sufficient or only further explanation is needed: not necessary to make additional or new code of conduct.
Writes a draft code of conduct based on analysis

10. Content and validation code of conduct
Content, style and presentation: big impact on success of code. The better the style, content and lay out the more it will appeal to the employees and inspire them in doing their job.
Possible structure draft code of conduct:
Strong commitment of management: e.g. introduction by top manager, competent politician…
Information on: application area (scope), goal, links with other integrity instruments and other rules and regulations, references to more information and sources
Text of code of conduct
Information on consequences of non compliance and breaches, information of where to raise concerns, possible sanctions

11. Content and validation code of conduct
Make code of conduct consistent with other applicable rules and regulations
Usually there are already applicable rules and regulations that have to be complied with such as staff regulations, rule of law, specific anti corruption law applicable to civil servants, rules on good public governance …
To get staff support to facilitate the implementation it is useful to:
Test/validate draft text with representative members of staff
Test/validate draft text with representative stakeholders such as political or management bodies
Consult unions as they defend the individual and collective rights of employees
Make a implementation and communications plan

12. Tips for appealing code of conduct
Write text in active, clear and understandable language
Include links and references to relevant applicable policies, rules, regulations, tools …
Make text and its lay-out in accessible, useful and easily browsable form
Make use of examples to make the rules and guidelines clear
Make sure that text is visually atractive and easily readable. Avoid long passages, make use of scanable lay-out with enough blanc spaces, appropriate fonts, no long paragraphs in italics or capitals…

13. Implementation of code of conduct
Make code known throughout organisation with support of management
In keeping with culture of organisation, code of conduct can be announced and made known in different ways e.g.
Article on code of conduct in company magazine, on intranet, internal news flashes, distribute posters in buildings of your organisation to promote code of conduct
Put integrity and ethics on agenda of team meetings, focus on specific items in code of conduct on appropriate moments e.g. on dealing with gifts and invitations in holiday period
Send code of conduct to all employees with personal letter/ by the boss/superior
Refer to appropriate item of code of conduct in speeches (team days, new year’s speech…)
Make service charter based on code of conduct, to be transparant and accountable to clients/society
Make accessible website on code of conduct with clear structure

14. Implementation code of conduct
Important: top management has to:
endorse code of conduct
set good example (ethical leadership key for compliance by employees)
Internal communication effective when regularly repeated:
different angles, different channels, top topicals… keep it interesting
Trainings on code of conduct and how to deal with relevant dilemmas:
in code of conduct values and guidelines seem logical but to apply them in different situations is more complex. Trainings learn employees to identify different stakeholders and their interests and weigh them against rules, regulations and values of organisation to reach ethical decision that will stand up to scrutiny.
Link code of conduct to broader integrity policy, HR policy, financial processes and procedures (e.g. public procurement)…

15. Implementation code of conduct
External communication: citizens/clients expect government to offer good service and to be trustworthy, ethical.
External communication about code of conduct can strengthen trust of citizens in government.
Code of conduct is ‘ethical calling card’ of government. (e.g. code of conduct on internet, ‘blue print letter’ to partners and suppliers to inform them on guidelines in code of conduct that also involves them)
Sanction policy: when code of conduct is not complied with or in case of integrity breaches, sanctions have to be applied. Enforcement is important, otherwise code of conduct loses its credibility. There should be:
no misunderstanding on sanctions and enforcement of code of conduct
organisation has to be consistent in its enforcement. A visible approach towards breaches and non compliance has a preventative effect and shows that organisation takes ethics and integrity seriously.

16. Follow up: keeping the code of conduct current and top of mind
After implementation important to keep focus on integrity and code of conduct. Organisation has to invest ample time, means and energy for follow-up. e.g. by means of :
Yearly employee survey on norms and values
Regular workshops and dilemma trainings
Discuss cases and dilemmas in teams and entities
Embed code of conduct in staff policies
Code of conduct is not static:
regular update to be in keeping with changes legislation, rules and regulations, culture, organisation structure, developments in society…

17. Contact integriteit@vlaanderen.be www.bestuurszaken.be/integriteit
Tel
LinkedIn: be.linkedin.com/in/kristienverbraeken