Good Governance and Social Responsibility 04 Worksheet 1: How Would You Describe The Code of Conduct of The Company?

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GOOD GOVERNANCE AND SOCIAL RESPONSIBILITY

04 WORKSHEET 1

TITLE: WHAT MAKE A GREAT CODE OF CONDUCT

1.  How would you describe the code of conduct of the company?

A code of conduct is a policy that outlines the principles and standards that all employees and
third parties acting on the company's behalf must follow. The code of conduct examines the
mission and values of the organization and links these ideals to professional behavior standards.
One way we put Google's values into action is through the Google Code of Conduct. It is based
on the recognition that everything we do at Google will and should be measured against the
highest possible standards of ethical business conduct.

2.  Are there ethics policies for participating in external professional, service,


charitable, or academic organizations?

3.  How do you rate the company’s ethical standards compared to other companies?

If I had to rate Google's ethical standards in comparison to other companies, I would give it a 10
out of 10 because, despite having a high standard and strict rules, it is one of the most successful
and influential companies in the industry. Google is only company on the list that provides
computer services. The powerful search and Internet advertising behemoth has a reputation for
being outspoken on a variety of social issues. According to my research, Google announced in
February that it would award one of its RISE Awards to Engineers Without Borders Australia, a
non-profit that works on computer science outreach with Aboriginal and non-Aboriginal girls.
Google grants the RISE Awards to organizations that promote computer science education and
assist girls and underrepresented minorities in technology. Since 2010, more than 200
organizations have received an award, and this year, 37 organizations will receive a total of $1.5
million to keep this vital effort humming along. According to the institute's website, these
organizations not only promote ethical business standards and practices internally, but they also
exceed legal compliance minimums and shape future industry standards by introducing best
practices today. This year's list includes 132 businesses from more than 50 industries. Ford
Motor Company, Dell, Xerox, and T-Mobile are among the other notable companies.
Companies today face a complex and often conflicting set of laws and regulations all over the
world, but despite the lack of a global rule of law, there is a growing consensus on how to do
business properly. Corporate social responsibility is not only gaining popularity among the
general public; it is also increasingly viewed as a business-enhancing trait, as stakeholders
ranging from employees and customers to executives and investors recognize that ethical
leadership drives outcomes ranging from operational performance to corporate integrity,
transparency, and workforce behavior.

4.  What is your overall perception of the code of conduct of the company?

My understanding of the Google Company's code of conduct is that the company is committed to
treating all workers with respect and dignity, ensuring safe working conditions, and conducting
environmentally responsible, ethical operations. They want all employees, including the board of
directors, to follow the code to avoid any harmfulness, harassment, bad treatment, or bad
attitudes; they want their employees to be respectfully guided by the code of conduct they
implement for the better and long-term success of the company.

5.  What suggestions do you have to improve the effectiveness of the code of conduct?

The successful implementation of a code of conduct is dependent on three critical elements:


proper definition, effective communication, and appropriate warning signals as monitoring tools.
Companies have been implementing corporate compliance programs for years that are generally
based on a published code of conduct and adhere to the infrastructure outlined in the Federal
Sentencing Guidelines for Organizations. To be effective, the underlying elements of each
program should reflect the organization's culture and management's operating style.

Disclosure of the code of conduct has not been consistent among companies. These are
suggestions based on today’s best practices:

 Write the code in a way that all employees can understand.


 Circulate the code internally to all employees on a regular basis (annually, at a
minimum). Require everyone to acknowledge that he or she has read it, understands his
or her responsibility to comply with it, and will report through appropriate channels any
observed violations.
 Circulate the code externally to institutional investors and other constituents.
 Publish the code in the company’s annual report and on its website.
 Conduct periodic employee training on the code and audits of the staff’s understanding of
it.
 Require periodic compliance self-assessments of selected employees using appropriate
code provisions.
A code devoid of discipline is devoid of substance. Management must take disciplinary action
for violations in a timely manner, and lessons learned from violations must be communicated to
employees and reinforced through training. Employees should be able to ask questions about
ethics issues and report ethical violations or breaches of company policy without fear of
retaliation if an internal reporting mechanism is in place.

These reporting mechanisms are frequently in the form of a "integrity hotline," though some
companies are establishing websites to receive reports and give reporting employees or outside
parties the option of remaining anonymous. Management should have protocols in place to
handle reported violations consistently, including the use of legal counsel, coordination with law
enforcement, and timely reporting to senior management and the board, in accordance with the
Sarbanes-Oxley requirements for reporting fraud.

Keeping an eye out for Ethics Red Flags

The board of directors of the company is responsible for three aspects of the code of conduct.
First, it must ensure that the code is consistent with the values that the majority of stakeholders
hold dear. Second, it must adhere to the code. Third, it must provide adequate oversight to ensure
that management is conducting business in accordance with the code.

The following key warning signs should be observed by directors. If these and other red flags are
identified, the board should conduct an investigation to determine whether there are any integrity
issues that require attention at the highest levels of the organization. There may be fire where
there is smoke:

Finally, whether or not a code of conduct is followed is the best indicator of its effectiveness.
When management's preferences, value judgments, and operating styles align with the highest
ethical standards, the organization is better positioned to maintain a quality reputation that
attracts and retains the customers, talent, and capital needed to grow the business and create
enterprise value. Strong corporate ethics breed positive business results in every industry.

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