The code of conduct, communicated to everyone, and the record to show it.

For compliance and legal teams who own the code of conduct, the speak-up policy and the rules behind them. Each one approved, sent to the people it covers, and on record by person and by version.

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Code of ConductVersion 4.2Owned by Compliance & Legal
Drafted
Compliance team
Philippa Foot, Chief compliance officer
Updated gifts and hospitality limits, a new AI section
28 Sep 2026
Step 1 · Legal
Karl Popper
General counsel
Approved1 Oct 2026
Step 2 · Board
Mary Midgley
Audit committee chair
Approved8 Oct 2026
Sent to everyone
All staff, 162 people
160 of 162

acknowledged version 4.2

The policies you own

The code sets the standard. The policies behind it each reach the people whose work they govern.

Code of conduct

One standard for everyone, and the document every investigator, auditor and partner reads first.

Speak-up and whistleblowing

How to raise a concern and how it is handled, where every employee can find it.

Anti-bribery and corruption

Gifts, hospitality and third-party payments, for the people who meet customers and agents.

Conflicts of interest

What to disclose and to whom, for directors, managers and buyers.

Sanctions and trade

Screening rules for the teams that sell, ship and pay across borders.

Data protection and records

What is kept, for how long, and how it is released, in step with the law.

Who asks to see them

Wherever you operate, prosecutors, regulators and partners ask the same question: was the policy communicated, and can you show it.

US DOJ, Evaluation of Corporate Compliance Programs

Communication of policies

Prosecutors ask how policies were communicated to all employees and relevant third parties, and whether there are language barriers to access.

  • Every policy sent to the people it covers
  • Third parties included as external users
  • Language versions kept current together

UK Bribery Act 2010, s. 7

Adequate procedures

The defence to failing to prevent bribery is adequate procedures, and the guidance names communication, including training, as one of its six principles.

  • The anti-bribery policy approved and current
  • Sent to every person who acts for you
  • Each acknowledgment by person and version

EU Directive 2019/1937, Articles 8 and 9

Internal reporting channels

Companies with 50 or more workers set up internal reporting channels, with clear, easily accessible information on how to report.

  • The speak-up policy where everyone can find it
  • Each language version kept current
  • Every change sent out again

Wherever you do business

Local laws

Each country adds its own rules on bribery, reporting, privacy and records. Each gets its own supplement beside the code.

  • A supplement for each country
  • Sent only to the people it applies to
  • Each change goes out again

Bring your own rules

Your region’s laws, the standards your customers ask for, and your own house rules. Write each one as a policy, approve it, and send it to the people it covers.

  • Laws of every country and state you work in
  • Standards and certifications
  • Customer and contract requirements
  • Your own policies and procedures
Check what your laws requirePolicy and Compliance lists the documents a business has to have in writing, by country and business type.Check your laws (opens in a new tab)

How it helps compliance and legal

Built for compliance officers and counsel who show an effective program to prosecutors, regulators, boards and partners.

Communication you can prove

Each person’s acknowledgment of each version, with the time and the statement.

The right policy to each role

Sales gets anti-bribery, buyers get conflicts, everyone gets the code.

Board approval on record

Add directors as approvers. Each approval is logged with the person and the date.

No seat cost for employees

Employees and other viewers are unlimited and free. You pay for the people who write.

Every change goes out again

A revised policy is approved, then everyone it covers is asked again, automatically.

Proof on request

Filter the record by date, person or policy and export a PDF or CSV.

Each role gets its own policies

Tag people by role, region and entity. Each policy reaches only the people it covers, and new hires get theirs on day one.

A record for every employee

Show an investigator or auditor who has acknowledged which version, with the time and the statement they agreed to.

Working with the rest of the company

Compliance writes the policy. Legal and the board approve it, and everyone else follows it.

Legal approves first

Add your general counsel as the first approval step. The policy waits for them.

The board signs off

Add the audit committee chair as a final step. Up to four steps, each with its own approvers.

Business leaders review their part

Bring the head of Sales in on anti-bribery, or Finance on payments, as approvers.

Each department keeps its own

Compliance edits compliance’s policies. HR, IT and Finance edit theirs, side by side in one place.

Agents and partners, inside the loop

Invite third parties as external users to receive and acknowledge your code.

Outside counsel, inside the process

Invite outside counsel as an external user to draft and review with you.

Ready for whoever asks.

Prosecutors, regulators, boards and partners ask the same thing in different words: the current policy, and proof it reached the people it covers.

Export the record as a PDF or CSV, or let them open the document directly.

  • Investigators and prosecutorsHow each policy was communicated, by person and version
  • RegulatorsPolicies approved and current, with their review history
  • Your boardApprovals on record, and acknowledgment across the company
  • Partners and customersYour code and anti-bribery policy, approved and current

Built around your compliance team

Roles and regionsTags such as Sales, Managers or Lisbon send each policy only to the people it covers.
Legal and the boardAdd them as approvers, one step after another.
Outside counselBring in outside counsel or a consultant as an external user to write and review.
AuditorsGive an auditor one document with a one-time code.

Need help writing the policies? Find a consultant for your standard.

Questions

Do employees need a paid seat?

No. They read, acknowledge and sign as viewers, free of charge.

Acknowledgment or signature?

Both are available. Choose for each policy when you send it. e-sign is an add-on on the Scale plan.

What happens when a policy changes?

The new version is approved, then sent to everyone it applies to, who are asked again.

Can an auditor see a document without an account?

Yes. Add them as a one-time viewer and they open that document with a one-time code.

Does everyone have to acknowledge again every year?

Only when a policy changes or expires. If nothing changed at review, the date moves and no one is asked again.

Can Compliance keep its policies separate from other departments?

Yes. Each department edits its own policies, and tags decide who reads them.

What happens to someone’s record when they leave?

Their completed acknowledgments stay on record.

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