Code of Ethics (cont'd)
- The mere existence of a code of conduct does not evidence its effectiveness.
- The code of conduct also must be communicated effectively
- Through the employee handbook, policy manual, intranet, etc., on a periodic basis to all covered persons.
- Employees should evidence their receipt and reading of the code.
- Annual Confirmations
- Requiring attendance at training, at the time of hiring, and periodically thereafter evidences the entity’s commitment.
- Ensuring the employees understand the code
- Both management and the audit committee are required to monitor the code of conduct.
2005 - Federal Transit Administration