Honesty, integrity, trust and fair play are essential attributes for all organisations.  The Federation urges employers to adopt a policy of “zero tolerance” of corrupt or suspect behaviour.  A well-written code can help prevent corruption and fraud, as well as build employer reputation.  The code should be written to provide an ethical and behavioural framework for employees at all levels.  It should also set out the guidelines on how to handle different situations in business dealings.

Features of an effective code of conduct

n            It should be

�          easy to understand.

�          accessible to all employees.

�          written to suit the needs of the employer.

�          clear as regards the method of control.

�          enforceable, practical, up-to-date and set in accordance with the fair competition principle.

�          regularly updated to keep abreast of relevant rules and regulations, e.g. Prevention of Bribery Ordinance, Sex Discrimination Ordinance, etc

�          comprehensive and cover guidelines of essential business manners, such as

-          offering, soliciting and acceptance of advantages

-          acceptance of entertainment

-          declaration of conflict of interests

-          handling of organisation information and property

-          channels for enquiries and complaints

n            Consultation and advisory service could be provided by ICAC to assist organisations in drawing up codes of conduct that suit their specific needs. Enquiries on the subject can be referred to the Hong Kong Ethics Development Centre of ICAC at http://www.icac.org.hk/hkedc/intro2.html

Enforcement of a code of conduct

For ethical practices stipulated in the Code of Conduct to be successfully enforced, the following should be noted:

Buy-in from top management

n            The management should encourage ethical consciousness within the organisation by being a role model in consistently upholding ethical principles and demonstrating ethical behaviour.

n            Managers should provide the right direction that is of particular importance when ethical dilemmas appear.

Communication and training of the code

n            Observation and compliance of Code of Conduct by all employees is the key to a “clean operation” of an employer. Since a single incident can jeopardise the employer’s image and the organisation, the “zero tolerance” message on any kind of malpractice should be well communicated.

n            Training or staff briefing should be conducted to ensure that employees understand the code.

n            As a good practice, refresher training should be arranged regularly or after the code is revised.

n            Briefing on the code should be included in orientation programmes for new hires.

n            Concrete examples or cases specific to the employer’s organisation should be illustrated for easy understanding of the code.

Confidentiality, fairness and impartiality in handling reported malpractices

n            To encourage employees to report on malpractices so as to maintain a “clean operation”, the message that employees’ identity will be kept confidential and that the case will be dealt with in a fair and impartial manner should be clearly communicated to the employees.

n            In the event that corruption or dubious practice is suspected, employers should refer the situation to the ICAC and not attempt to deal with it internally.

Regarding the features and the enforcement of an effective Code of Conduct, some useful tips are given in Appendix VII.