Formulating a Company Code of Conduct


The management should formulate a company code of conduct according to the specific needs of the company for staff’s compliance in conducting business.

7 key elements of a Company Code of Conduct

  • Prohibit illegal offer or acceptance of advantages
  • Avoid offering or accepting excessively lavish entertainment
  • Remind staff to pay attention to conflicts of interests
  • Prevent abuse of company propriety information or property
  • Seek prior approval from company for outside employment
  • Use company information and communication systems properly
  • Specify enquiry or complaint channels

Moreover, the company should inform all suppliers or contractors about the company’s stance and policies on acceptance of advantage by staff, and encourage them to report any illegal solicitation of bribe.


The Sample Code of Conduct produced by the ICAC is also a good reference for companies to develop their own code.

Please click here to view the Sample Code