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March 2010
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HZ Jeep dot com

Business & Management Resources

Annual Review


Your company’s code of conduct should be formally reviewed at least annually by your ethics compliance officer or ethics committee, as well as by your company’s CEO and board of directors. This review should be more than perfunctory. It should include an active inquiry into and analysis of how effectively your company’s code of conduct has been communicated to your employees, how well your employees have been educated and trained on ethical and legal conduct and compliance, and how well your code has been enforced and reinforced. Particular attention and review should be directed to any waivers of your code that may have been granted in the past year, particularly for senior officers or directors.

Transgressions of your code, particularly if they are repeated, should result in revisiting your code and your ethics training program to reassess whether further corrective action, training, or education needs to be undertaken to prevent future reoccurrences of the same illegal or unethical behavior.

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