Code of Conduct and Ethics and Whistleblowing Policy

Summary

This template is a code of conduct and ethics and whistleblowing policy that covers many topics to help educate employees of their responsibilities. It includes information for employees on making whistleblowing complaints and non-retaliation language for whistleblowers. This template includes practical guidance and drafting notes. This template is intended for private employers. It is based on federal law and does not address all potential state law distinctions; thus, you should check any relevant state and local laws. Below is a chart with data from the SEC showing the type of whistleblower tips in 2023. Source: SEC data. You should assist the employer in adapting this Code of Conduct and Ethics and Whistleblowing Policy as necessary to fit the business and circumstances of the employer. For a full listing of key content that can be used by in-house counsel to develop, revise, and implement a company's employee and third-party-related policies, see In-House Company Policies Resource Kit. For a full listing of key content covering a wide range of compliance-related practice area topics, see In-House Compliance Resource Kit. For a full listing of key materials necessary to develop consumer-related bank policies and procedures central to regulated depository institution operations, see Developing Bank Policies and Procedures Resource Kit. For a full listing of key content covering management of in-house legal departments, see In-House Legal Department Management Resource Kit. For a full listing of key content covering employee handbook considerations, see Employee Handbook Resource Kit. For information concerning codes of conduct and ethics and whistleblowing policies, see Code of Conduct and Ethics (Corporation), Employee Codes of Conduct: Key Drafting Tips, and Whistleblower Policies, Programs, and Investigations. For videos on whistleblowing from an employee’s perspective, see How to Speak Out & Listen Up: Part 1 Video and How to Speak Out & Listen Up: Part 2 Video.