// By Douglas Allen

In the past year or so, Ethisphere has put over 500 Codes of Conduct under the microscope, and in our reports we’ve highlighted some excellent Codes and some that, frankly, have plenty of room for improvement.

Happily, several organizations whose Codes did not fare well against our benchmarking methodology have returned to us with an updated Code in hand. Often, the new Codes are crafted with our feedback in mind, and as a result, they are dramatically improved.

While Ethisphere is known for drawing attention to those companies who attain Code nirvana, we rarely discuss the process taken by companies that have revamped their lackluster codes into solid, engaging Codes of Conduct.

Recently, we caught up with two Cisco Systems executives, Jeremy Wilson, Manager of Cisco’s Ethics Office, and Christine Style, Ethics Marketing Communications Manager, to discuss how their team pursued the recent makeover of Cisco System’s Code of Business Conduct.

E: What were some of the biggest hurdles faced during the revision process?
JW: One of the biggest hurdles we confronted was managing the project team that required accurate input from so many sources. We created a comprehensive project plan to manage the process that made sure everything was being worked and according to our desired timeframe.

E: What areas of the Code underwent the most dramatic changes?
JW: By bringing the document down to an eighth-grade reading level, people are finally able to understand the whole Code and, more importantly, relate to its content. Involve your corporate communications department on this project. They have the expertise to develop the content for your workforce in an engaging and comprehensible style.

E: How has the organizational culture changed at Cisco as a result of the code revision?
JW: The new Code received extremely positive feedback and has prompted many executives down to individual contributors to seek out the Ethics Office’s presence at upcoming meetings and events. More people are speaking up than ever before. People are finally feeling comfortable asking the questions, before acting.

CS: Having rolled out the new COBC at the same time as our annual certification enabled us to create momentum and awareness on the new direction and format of the document.”

E: What kind of momentum did Cisco experience?
CS: 99 percent of 53,500 worldwide employees certified within the eight week campaign period.

E: Any words of wisdom for those organizations beginning the Code revision process?
JW: Don’t reinvent the wheel. Others have paved this path before you. There is much to be learned from them. Reach out to industry partners or even competitors. It is likely they will be very open to your desire to work together.

I also advise looking to resources outside your department. Your program does not likely possess all the skills required in order to create a world-class Code of Conduct from scratch. Look to subject matter experts, Corporate Communications, Investor Relations and Public Relations for input on the front end of the project. Understanding how to navigate the communications world within your company before you begin will save you much time and greatly enhance your final product.

E: Any parting thoughts?
JW: Often companies are reluctant to change their Code of Conduct because it is such a big undertaking or because “Legal would not like it.” Understand that you are an agent of change and that it often must begin with you. Do not be afraid to start your Code over from scratch, and question the old document in its entirety. Just because it was written a certain way 10 years ago does not mean that it should continue to be written that way.

Also, get creative. Compliance related topics are inherently dry. Find a way to connect with your Code and your employees. Once that connection is made, the path is paved for you to enhance your organization’s ethical culture.