Code of conduct project

Situation: This global diversified mining company had a robust governance structure but lacked a code of conduct. The company wanted to ensure that it was prepared for the implementation of the 2010 UK Bribery Act and that it met corporate governance standards in the UK and Australia.

Challenge: To assess the key ethical or business conduct risks and draft a code of conduct consistent with the company’s extensive health, safety, environment and community and other policies, standards and procedures.

Action: The project was undertake in two phases:

Phase 1 (Research Phase):

 Desktop review of risk registers, fraud and ethics line reports

Benchmarking analysis of leading codes of conduct content undertaken

Interviews with 12 executives to understand key risks, cultural challenges, effectiveness of the internal whistleblowing system and the current training program

‘Decision-making model’ designed

Board input - Prepared input for board meetings on the process of developing an ethics program

Final report - Prepared a report including matrix of key risk issues, cultural challenges and recommended training needs

Phase 2 (Code of Conduct Drafting)

Drafted Code – a detailed code of conduct was written.

Training materials - Drafted scenarios for use in training for managers

Training program - Developed a ‘train the leader’ and ‘train the trainer’ program

Results: The company’s code of conduct was developed, approved and published. The content was based on the risk assessment process, the benchmarking exercise and input from a range of internal stakeholders. Targets were set by the corporate area for training and development in the business units in relation to the code of conduct.