A code of ethics has to reflect the values the company holds to and the way in which it wants its business to be conducted. Those corporate values should be long term and so need little change over time, but changes to the company’s business need to be reflected in the code.
So if your sales function is being overhauled or services to clients significantly expanded, then a review of the code should ensure that it continues to reflect the ethical risks and opportunities faced by the company. Change can come from outside the company as well, such as through new laws such as the Bribery Act 2010 or renewed concerns over issues such as conflicts of interest or client confidentiality.
A code that doesn’t change slowly but surely turns into a code that becomes ignored. Often, all that is required is a greater emphasis here and there, some extra detail around a particular point or a link to a more recent policy initiative. What I bring to such reviews is a critical friend role to help the company identify the right issues, weigh up the options and get the emphasis right. Having written a great many codes myself, I’m able to bring that outside perspective to your review and ensure that it delivers a code that makes a difference to how your people work.
Duncan is an independent adviser on business ethics, with a particular focus on the insurance and financial planning sectors. He worked in insurance for 18 years and has been an ethics adviser for 11 years. He's a Chartered Insurance Practitioner.