It’s always useful to look at what your competition is doing. The same is true in drafting your code of conduct (or code of ethics or whatever name you chose). It is useful to look at you what your competitors’ codes of conduct look like.
Since Sarbanes-Oxley requires a public company to have a code of conduct, its fairly easy to dig around the investor relations portion of their website or SEC filings to get your hands on examples.
Since my company is a real estate company, I put together a database of Codes of Conduct for Real Estate Companies.
My original goal was to find codes for other real estate private equity companies. I struck out.
So I expanded to public REITs and real estate investment advisers. All of the companies in the database are public.
So far I have not found a private real estate company that has published its Code of Conduct. This is what I expected and not a criticism. In fairness, I haven’t publicly published my Code of Conduct.
With compliance, it’s better to think of competitors as peers instead of the competition. You might get some market gain with a competitor lost to a compliance or ethical failure. You’re more likely to get more government oversight and regulation, less of investor confidence and many more headaches.
Image of Columbia Center is by simonsonjh from Wikimedia Commons