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Integrity & Compliance OfficeDepartment of Assurance Services

Jaycee L. Dempsey, MBA, CCEPSenior University Integrity & Compliance Analyst

Jacqueline L. Kniska, JD, CHCUniversity Integrity & Compliance Officer

Creating an Interactive,

User-friendly Code of

Conduct on a Lean Budget

VCU at a glancePublic Urban Research University

11,388

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Where to begin?

Best Practices

Developing a Working Draft

Involving StakeholdersThis image cannot currently be

displayed.

Communicating Your Code

Training & Measuring Effectiveness

overview

This symbol means there is an

associated resource or tool available.

why do you need a code?

Purpose: Outline and explain the expected behaviors, values

and standards that guide employee decisions

To clearly articulate existing expectations

� Summarize ethical standards, values and key policies

� Provide resources for additional guidance

� Ensure understanding that all employees are responsible for meeting the university’s expectations

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Phase I: development process

Assemble a committee &

create an outline

Research best

practices

Developing a

working draft

Gather

committee feedback and revise

Gather key

stakeholder feedback and

revise

Benchmark

your code

Gather

feedback from all

employees

where to begin?

Create an Outline

Feedback

Identify topics/

risks

Review other Codes

Assemble a committee & create an outline

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development process

Assemble a

committee & create an

outline

Research best practices

Developing a

working draft

Gather

committee feedback and revise

Gather key

stakeholder feedback and

revise

Benchmark

your code

Gather

feedback from all

employees

development process

Research best practices

� Other corporate and academic codes of conduct

• Codes graded an “A” or above in Ethisphere’s database

• Peer institutions

� Recommendations from consulting agencies

� Code of Conduct whitepapers

See Resource Links.pdf

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best practices

Availability � Online availability, easily accessible, downloadable and print friendly

Tone from the Top/Middle � Letter from the president and support of senior leadership

� Letters/messages/quotes from VPs Compliance Officer and/or others leaders

Readability & Tone of “Voice”

� Between 8,000 – 10,000 words

� Inclusive tone that is not overly formal and refrains from legal jargon

� Readable by all employees at every level (translations?)

Non-Retaliation & Reporting � Outline reporting options for actual or perceived violations of the code

� Commitment to non-retaliation for good-faith reports

Core Values � Express commitment to core values to all stakeholders (including employees,

students, vendors and local communities)

Risk Topics � Address all of the major risk areas

Practical Guidance � Learning tools within the Code, such as Q&As, FAQs, examples, links, quizzes

Presentation & Style

� Logical organization based on values or risk topics

� Easy navigation – Table of contents, index, hyperlinks, arrow buttons, etc.

� Visual Appeal and branding – logo, colors, terms, images, white space, layouts

development process

Assemble a

committee & create an

outline

Research best

practices

Developing a working draft

Gather

committee feedback and revise

Gather key

stakeholder feedback and

revise

Benchmark

your code

Gather

feedback from all

employees

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developing a working draft

Collect topic language from:

department websites policies governing documents

and then…

EditReplace complex wording

(legalese/academese) with plain language

Edit some more

Be concise and link to additional information (policies, websites, etc.)

Edit again!

Revise to be positive, inclusive tone (“we” and “our”) rather than policy text

1 2 3

developing your working draft

Remember your goals and objectives:

� Create a user friendly reference tool

� Clarify and summarize expectations for

both faculty and staff at all levels

� Provide examples

� Provide learning aids and tools

� Link to resources for more information

� Intuitive organization

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VCU’s Code organization

See VCU Code of Conduct.docx

links to related policiesethical decision-making

practical examples

VCU’s Code: key features1

2

3

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interactive features

Downloadable tools to help employees easily recognize red flags or evaluate decisions

Hyperlink/bookmark resources both internal and external to the document

Searchable by keyword

Videos and animations

Self assessment quizzes

Rollovers/Mouseovers - definitions, graphics, additional guidance, Q&As, etc.

development process

Assemble a

committee & create an

outline

Research

best practices

Developing a

working draft

Gather committee

feedback and revise

Gather key

stakeholder feedback and

revise

Benchmark

your code

Gather

feedback from all

employees

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committee review

Collect feedback from committee members

� Several revision cycles may be necessary

� Consider and incorporate feasible suggestions

� Explain why any changes were or were not made

• No current policy on the topic exists

• Contradiction of policy

• Information is elsewhere in Code

• Too specific to one area (not applicable universitywide)

development process

Assemble a

committee & create an

outline

Research

best practices

Developing a

working draft

Gather

committee feedback and

revise

Gather key stakeholder

feedback and revise

Benchmark

your code

Gather

feedback from all

employees

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stakeholder review

Collect feedback from additional stakeholders

� Identify stakeholders outside of your committee

• Faculty and staff senate (executive/steering groups)

• Compliance Advisory Committee members

• Risk topic owners not on compliance committee

• Council of Deans

• Cabinet (President and Vice Presidents/Provosts)

• Legal Office

• Current code owners (if applicable)

• Task forces assembled to address any code-related issues

stakeholder review

Create a timeline (consider breaks & holidays)

Give due dates!

Collect, consider and incorporate suggestions

Thank stakeholders for their inputThank you!

Suggestions

August 5

Begin Review

September 5

Feedback Due

Labor Day September 26

Revise Draft

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development process

Assemble a

committee & create an

outline

Research best

practices

Developing a

working draft

Gather

committee feedback and revise

Gather key

stakeholder feedback and

revise

Benchmark your code

Gather

feedback from all

employees

benchmark your code

Free! Code benchmark performed by

VCU’s Draft Code of Conduct Overall GradeA

#1 reviewed #1 reviewed #1 reviewed #1 reviewed code in code in code in code in eeeeducation ducation ducation ducation iiiindustryndustryndustryndustry

See Resource Links.pdf

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development process

Assemble a

committee & create an

outline

Research

best practices

Developing a

working draft

Stakeholder

review

Revise based

on stakeholder

feedback

Benchmark

your code

Gathering feedback from all

employees

collect feedback & questions

www.codeofconduct.vcu.edu

� Open Forums

� Feedback form on website

See Resource Links.pdf

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development process

FIN

AL S

TEPS Review Employee

Feedback

Make Final Edits

Post to Website

Phase II: communicating your code

� Promo items

� Broadcast emails

� Broadcast voicemails

� Newsletters

� Open forums

� Posters

� Mailers

� Links on university websites

� Brochure/handout in new

hire packets

� Toolkits for managers

� Adding links/QR codes to

paystubs

� Performance Evaluation

� Pocket/mini codes for print

� Desktop shortcuts to code

Develop a plan and timeline

Awareness initiatives to consider:

Be creative!

See Communication Tools folder

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Phase III: measuring effectiveness & leveraging into training

Measure your code’s

effectiveness

� Web statistics – how many

views, time spent, etc.

� Word of mouth feedback

� Survey employees

� Comprehension quizzes

Training and education

� Integrate into current

training

� Standalone Code training

See VCU Code Training Course folder

other considerations

An online only code is:

� Easily updated

� Less expensive

�

Consider a portal page with:

� Kudos to ethical employees

� Endorsements from your affinity groups

� Related articles

� Blog

� Relevant links

Acknowledgement/Attestation at hire, annual or

biennial?

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lessons learned & questions