A Code of Conduct is the foundation of an effective organization-wide compliance program. It provides a map for employees, directing them to use organizational values in their daily decision making.
An effective Code of Conduct should:
- Incorporate organizational values
- Improve awareness of compliance risks
- Determine wrongdoing and promote honest and ethical conduct
- Identify clear methods of reporting compliance concerns
- Increase employee and key stakeholders’* trust in the organization’s commitment to compliance
To ensure relevance and dissemination, the Code of Conduct should be:
- Readable and accessible to employees and key stakeholders*
- Reviewed annually to incorporate latest developments in laws, regulations and risk areas
- Included in initial orientation training
- Acknowledged by all employees and key stakeholders annually
A thoughtful, well written Code of Conduct will serve the organization and the employees by providing guidance and reinforcing the organization’s commitment to compliant and ethical behavior.
*Key Stakeholders: see below for further considerations regarding stakeholders
For additional resources, check out these websites:
SAI Global Whitepaper
OIG Compliance Program, Guidance for Hospices
OIG Compliance Program, Guidance for Home Health Agencies
When drafting compliance documents, such as the Code of Conduct or policies and procedures, and when considering how best to educate and enforce, it is important to decide how you will address all key stakeholders related to your organization. These may include:
- Employees *
- Owners (if applicable)
- Board members
- Joint venture partners
- Vendors of outsourced services
- Other vendors
* Depending upon the size of your organization, employees could be further segmented by job function or geographic area.
You may decide to develop one document applicable to all stakeholders, individual documents geared to a certain group of stakeholders, or a document that is generic but may have different elements such as a cover letter to a Code of Conduct that is targeted toward different audiences.
The bottom line is that you want to ensure that all stakeholders are addressed and brought into your compliance program.
Prepare. Reinforce. Go Further.
TCG Compliance Solutions is ready to assist you in implementing and enhancing effective controls and best practices for seamless compliance.
Contact us for the necessary expertise, resources and tools to improve and maintain compliance.