// BY DOUG ALLEN

As devotees of Ethisphere are aware, each issue of the magazine features 50 Codes of Conduct benchmarked and assessed. Some of those codes are great, and others are forgettable. In that section, Ethisphere Magazine is proud to acknowledge those organizations that put forth the time and effort to develop impressive and meaningful codes of conduct. Of course, this praise becomes more effective when contrasted against those organizations that opt to settle.

By wading through hundreds of codes, we see that today’s great codes entirely humble the relics of the past. Leading companies no longer use stuffy lawyers to dictate what constitutes inappropriate behavior. Astute organizations are seeing their codes as an opportunity to communicate behavioral expectations surrounding key risk areas, instill organizational values and convey a broad ethical culture and credible tone from the top.

Revising an existing, less-than impressive code is no easy task and we don’t encourage anyone to undertake this project alone. To help inspire organizations that want to revise their code, we caught up with Kathleen Hammock, vice president and chief compliance officer of the St. Louis based pharmaceutical benefits management company, Express Scripts. Hammock recently oversaw the creation of her company’s excellent new code. She gave us a simple five-step checklist for companies to review when undergoing their own code makeover:

1. Set goals first.
   We at Express Scripts used the Ethisphere benchmarks as our goals for improving our code. I think one of the most important concepts we got from Ethisphere is the idea of embedded learning aids to help illustrate concepts that were dense.
2. Figure out what traits of a good code fit your organization.
   We read a ton of codes that earned a high grade from Ethisphere, and narrowed our selection down to the ones we liked. We also read a lot of codes that received a low grade. Throughout, we talked about what would work at Express Scripts and what would not. We also banned copying. We (my compliance team) talked a lot about the ones we liked and most importantly, why we liked them. Discussion was almost always ad hoc, not in meetings.
3. Start with an outline that is legally complete, then re-write it a lot.
   Express Scripts’ compliance director (a non-lawyer) did the first draft. I did the second draft (I am a lawyer) and really tried to completely ditch big words and the legalese that remained. Then we had most of our lawyers take a stab at editing it. We probably had at least seven different people make edits to the drafts. They were great sports at keeping the legalese out of the draft.
4. Give it to the professional writers.
   We gave our draft to our in-house communications team, showed them the Ethisphere benchmarks, had them read some codes that were graded highly and told them we wanted an “A.” This step really paid off because reading the other codes and seeing the benchmarks really clarified our expectations. The first draft they gave us was 90 percent there. The other thing the communications team did for us was to rewrite the language again from a fresh point of view. They were able to use better and simpler words that we didn’t even think of because we were too close to it.
5. Give lawyers the final review.
   But tell them that their review is for legal sufficiency only. We banned them from word-smithing (goodnaturedly, of course). It worked. They found a couple of items that really needed to be changed.

After following those steps, what were her results? “We have been stunned at the impact the new code has had on our organization,” Kathleen says.

The impact has resulted in much more than just a pretty document for Express Scripts employees to look at—it has positively affected the overall corporate culture. On top of that, it’s also resulted in greater distribution.

“We have had a significant rise in inquiries,” explains Kathleen. “We had people graciously tell us that they picked it up and ‘actually read it.’”

And after all, isn’t that the point?