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Code of conduct policy: what to include and what to decide first

What a code of conduct must settle: four management decisions, the behaviour to spell out, the path a concern takes, and a sample outline to adapt.

Ganesh HS · · 8 min read

Two HR policy advisers reviewing a printed handbook together in a bright meeting room.

In brief

  • The code is the umbrella policy; it names the behaviour expected and points to the detailed policies on gifts, data, devices and complaints.
  • Four decisions shape it: reporting authority, the disciplinary process, conflict disclosure and gift limits.
  • Every concern needs a second route for cases where the named person is the problem, kept in a restricted case file.
  • Staff acknowledge each version in writing; the code is reviewed yearly and after any serious case.

A sales executive accepts a Diwali hamper from a vendor at a festival and tells nobody. A team lead mocks a colleague in a WhatsApp group that a client has also joined. A developer runs a weekend consultancy for a competitor. None of these people think they have done wrong, because nobody told them where the line sits. A code of conduct exists to draw that line before the situation arrives.

Purpose and who the code covers

The code states how people are expected to behave toward each other, toward customers and vendors, and toward the company's name, money and information. It is the umbrella policy. The detailed rules on gifts, data, devices and complaints sit in other documents, and the code points to them.

Decide the scope in one sentence. Most companies cover directors, employees, interns, trainees and anyone working on the company's behalf, in the office, at a client site, on calls and on official online channels. If you want it to reach consultants and freelancers, say so, and expect to attach it to their agreements as well.

Terms that need a plain meaning

Define the words that cause arguments later. Harassment, bullying, intimidation, conflict of interest, gift, confidential information and official channel all need one short definition each. Write them with examples from your own workplace rather than copying dictionary lines. A definition that mentions a client dinner or a group chat is easier to apply than one that talks about improper advantage.

The decisions management has to take

  • Reporting authority: who receives a concern about conduct, and who receives it when the concern is about that person.
  • Disciplinary process: who investigates, who decides, and what the employee is told at each stage.
  • Conflict disclosure: what must be declared, to whom, and how often.
  • Gift limits: whether gifts are allowed at all, the value above which they are declared, and the value above which they must be declined.

Reporting authority is the choice with the most consequence. Naming the line manager alone fails when the manager is the problem. Naming HR alone fails in a company where HR is one person. Most small companies name two routes, such as the manager or the HR head, plus a director for matters involving either of them.

On gifts, a flat ban is easy to explain but tends to be ignored for small tokens. A declared threshold keeps the rule believable. The trade-off is that someone must keep the gift register and read it. Pick the version you will actually maintain.

Behaviour the code should name

Keep this part concrete. People remember examples, not principles.

  • Respect toward colleagues, customers, vendors and visitors, including how people speak in meetings and on customer visits.
  • No discrimination, harassment, intimidation or bullying, with examples of each in plain words.
  • Honesty in reports, timesheets, expense claims and customer statements.
  • Careful use of company property, information and accounts.
  • Confidentiality of business and customer information during and after employment.
  • Conduct on official channels and on personal social media when the company is named or identifiable.
  • Cooperation with any inquiry, and no retaliation against someone who raised a concern.

Workplace discipline and etiquette also belong here, but keep them light. Punctuality, dress at client sites and courtesy in shared spaces can be set in one short paragraph that points to the attendance and working hours policy for the detail.

How a concern moves through the company

  1. 1

    Raise

    The employee tells the named authority in person, by email or on the conduct concern form. Anonymous notes are accepted if you choose to allow them.

  2. 2

    Log

    HR opens a case entry with a reference, restricted to the people who need to see it. It does not go into the ordinary request queue.

  3. 3

    Assess

    The reporting authority decides whether the matter is a misunderstanding, a minor lapse or possible serious misconduct.

  4. 4

    Respond

    The person concerned receives the facts in writing and a fair chance to explain, with the date for a reply.

  5. 5

    Decide

    The disciplinary authority records a proportionate outcome and the reason for it.

  6. 6

    Close

    HR tells both sides the outcome that concerns them, files the record and notes any change to training or process.

Complaints about sexual harassment follow their own route and are not handled in this queue. The disciplinary and grievance policy covers the full procedure from complaint to closure.

When the code is broken

State that violations can lead to action ranging from guidance and a written warning up to termination, and that the action is proportionate to the act. Do not promise a fixed penalty for each breach. A fixed list removes the room to treat a first honest mistake differently from a deliberate act. Say who has the authority to issue each level of action, and that the employee always gets a chance to respond before a decision.

Decide whether suspension during an inquiry is available, and under what conditions. If so, write that it is not a finding and that pay and benefits during it follow the contract and the law.

Records, acknowledgement and review

Collect a signed or digital receipt from every person, showing the date and the version they accepted. Keep the gifts register, the declaration forms and the conduct case file under restricted access. Review the code once a year and after any serious case, record what changed, and issue a new version number. Existing staff re-acknowledge when the version changes.

Sample outline: Code of Conduct (HR-POL-001)
1. Title and ID: Code of Conduct, HR-POL-001, version [number]
2. Purpose: this code sets the behaviour expected of everyone working for [company name].
3. Scope: directors, employees, interns and [other groups], in every place and channel where they act for the company.
4. Definitions: harassment, bullying, conflict of interest, gift, confidential information, official channel.
5. Policy statements: conduct toward people; use of property; gifts above [value] are declared to [role]; outside work needs written approval from [role].
6. Procedure: concerns go to [role] or, if the concern involves that person, to [director role]. The conduct concern form is the record.
7. Roles: employees follow it, managers model it, HR keeps the registers, the disciplinary authority decides outcomes.
8. Exceptions: only [role] may approve, in writing, with the reason recorded.
9. Violations: action proportionate to the act, after the employee has had a chance to respond.
10. Related forms: conduct concern form, gift and hospitality register, annual declaration.
11. Effective date, version, review: reviewed every [number] months.
12. Receipt: I confirm that I have read this code, understand it and will follow it. Name, date, version held.

GullyHR drafts and reviews such documents as part of HR policies and governance. If gifts and outside interests are your main worry, read the guide to the conflict of interest policy, and the order in which to write all thirty policies if you are starting from nothing.

Questions we are asked

That depends on the gift threshold your company sets. Common practice is to declare anything above a set value and to refuse cash always. Check the gift clause, and if you are unsure, declare it. Declaring a gift that turns out to be allowed costs nothing.

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