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Code of Ethics and Professional Conduct

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The foundation of an organization’s compliance and ethics program is its Code of Ethics and Professional Conduct (“Code of Ethics”). Clear Law Institute works with organizations to (1) create their first, custom Code of Ethics, or (2) update and improve their existing Code.

A Code of Ethics details your organization’s culture and values and sets specific expectations for how employees should act on a day-to-day basis. The Code of Ethics also describes the steps employees must take to comply with various laws.

An effective Code of Ethics has the following qualities:

  • Promotes compliance. The Code of Ethics provides guidance on how employees must comply with relevant laws that impact employees’ day-to-day work.
  • Promotes adherence to company values. An effective Code of Ethics details company policies that employees must follow.
  • Encourages a speak-up culture. An effective Code of Ethics encourages employees to seek guidance when they have questions about complying with the Code and also to report concerns about potential Code violations.
  • Is easy to read and understand. An effective Code of Ethics is written in a clear, easy to understand style, and does not include legal jargon.
  • Provides examples. An effective Code of Ethics gives examples of difficult scenarios that employees may face in real life and provides guidance on how employees should handle these issues.


The content of a Code of Ethics will vary depending on your industry, your employees’ locations and job duties, and your organizational values. Clear Law’s Compliance Advisory Team will work with you to determine what specific topics to address based on your values and applicable law.

Codes of Ethics often address the topics below:

  • Application of the Code of Ethics
    • Who Must Follow Our Code?
    • What If I Have a Code-Related Question or Concern?
    • Reporting Concerns
    • Anti-Retaliation
  • Company Values
    • Usefulness
    • Responsiveness
    • Taking Action
    • Respect Each Other
    • Tone at the Top
    • Fairness
    • Accountability
  • Legal Requirements
    • Trade Controls
    • Competition and Antitrust Laws
    • Insider Trading Laws
    • Anti-Bribery Laws, including the FCPA
    • Gifts and Entertainment
    • Dealing with government officials
    • Privacy, Security, and Data Protection
  • Conflicts of Interest
    • Personal investments
    • Outside employment, advisory roles, board seats, and starting your own business
    • Business opportunities found through work
    • Inventions
    • Personal relationships at work
    • Accepting gifts, entertainment, and other business courtesies
    • Use of our products and services
  • Confidentiality
    • Safeguarding confidential information
    • Trade secrets and intellectual property
    • Disclosures to the media, partners, and family members and friends
    • Competitors and former employers
    • Outside communications and social media posts
  • Company Assets
    • Intellectual Property (trademarks, logos, copyrights, trade secrets, “know-how”, and patents)
    • Respecting IP rights of others
    • Company Equipment
    • Our Network
    • Physical Security
    • Use of Our Equipment and Facilities
    • Privacy of Employee Data
  • Financial Integrity and Responsibility
    • Internal Controls
    • Spending company money
    • Documentation of contracts
    • Recording Transactions
    • Reporting Financial or Accounting Irregularities
    • Hiring Suppliers
    • Retaining Records
  • Fair and Safe Workplace
    • Equal Opportunity Employment
      • Harassment and Discrimination
      • Reasonable Accommodations
      • Bullying
    • Drugs and Alcohol Policy
    • Safe and Healthy Workplace


We offer a fixed fee to develop your Code of Ethics. Because Clear Law Institute provides compliance training and consulting services for more than 1,500 employers across the country, we are able to spread the development costs of our services across a large customer base. As a result, our prices are almost always much less expensive than working with a lawyer or law firm.

To learn more and receive pricing information, please Schedule a 30-minute Free Consultation.

Clear Law Compliance Advisory Team

Unlike many training providers that have wandered into the harassment prevention training space, Clear Law Institute is a compliance services company. Our in-house team of compliance advisors has more than 60 years of experience in employment law compliance matters. The following compliance experts lead our team:

Michael Johnson, J.D., CEO of Clear Law Institute, is a former U.S. Department of Justice attorney who brought one of DOJ’s first “pattern or practice” sexual harassment cases. Mike has provided training and consulting on harassment prevention and investigations to organizations around the world, such as the EEOC, the United Nations, and Google. He is a graduate of Duke University and Harvard Law School.

Alicia Daniel, Senior Compliance Advisor, has advised on highly regulated fields in both the private and public sectors. She served clients as an associate at Foley Hoag LLP, specializing in investigation defense, healthcare law, and cannabis licensing. From there, she joined the Massachusetts Office of the State Auditor, where she advised the agency on employment and compliance matters as Deputy General Counsel. She graduated with honors from Oklahoma Baptist University and Harvard Law School.

Teresa Harvey Rollins, J.D., Senior Compliance Advisor, has nearly 20 years of experience representing Fortune 500 companies and other employers on a broad range of employment matters, including discrimination and harassment prevention. Tes previously practiced law as Counsel at Dickstein Shapiro and was CEO of PolicyPartner LLC, an employment compliance service provider. She is a graduate of Angelo State University and Southern Methodist University’s Dedman School of Law.

Brian Rothenberg, J.D., Senior Compliance Advisor, has advised hundreds of organizations on their compliance training and other compliance needs. An attorney by training, Brian understands both the legal requirements and the other competing challenges organizations face when rolling out compliance training or services. Brian is a graduate of the University of Richmond and the Marshall-Wythe School of Law and the Mason School of Business at the College of William & Mary.

Clear Law Institute provides online compliance training for more than 1,000 clients, including:

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