Code of Conduct awareness and engagement: Treat your code Like a marketing campaign

Think like a marketer to drive engagement with your Code of Conduct (and improve compliance)

June 13, 2022

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Marketing campaigns drive initiatives forward, pushing users to enact certain behaviors, typically to encourage a sale. Can marketing tactics help you drive better outcomes in your code of conduct training? Could they lead to more ethical behavior, providing tangible and measurable results?

We believe they can.

In this post, Asha Palmer, Chief Ethics and Compliance Officer at OneTrust, will walk you through the steps needed to effectively market your code of conduct to employees.

Why you need to think like a marketer to build code of conduct engagement 

Behavioral science teaches marketers what kinds of messages their audience is attracted to and how marketing can drive specific behaviors. On the other hand, compliance officers often communicate in fact-based legalese that is sometimes focused more on negative outcomes than on telling a compelling story. Changing the dialogue about compliance has the potential to change the way employees and organizations interact with our department and humanize those messages in a way that truly makes an impact.

“In compliance, we tend to take a one-size-fits-all approach,” said Asha. “You disseminate your Code of Conduct and compliance training to your executives the same way you disseminate it to factory-level employees. Any person can tell that it’s not a message tailored to them, and that leads to less buy-in. Your message needs to change with each persona because the way they interact with it leads to different outcomes.”

“I took it on as a mission to understand how we make this subject relatable and approachable in a way that drives the engagement. That’s the same approach we have to take within our companies. We need business people to stop and think before paying a bribe. We need business people to know that cooking the books is not right. And if they can’t get that from the training that we’re giving them, how do we change our approach? By thinking like a marketer.”

“Marketers are amazing at conversions because their end goal is to make you take action. Our action in compliance is different from buying something, but we still need to drive that action.”

Step 1: Develop code of conduct personas 

Before planning your Code of Conduct awareness campaign or a training message, you must first understand how and where each audience type will interact with and meet them where they are.


  • Location
  • Timing
  • Tone
  • Relatability

Personalized training for the executive level means considering ways executives may be influenced to behave outside of the Code of Conduct. Executives likely won’t be meeting on a factory floor, so distributing the messaging via posters in the break room completely misses that persona. Similarly, shift supervisors and line workers may not log in regularly to the company intranet or transmit information digitally. Code of Conduct rules about distribution of confidential information mean something different to those unique personas. Understanding how those Codes apply to the roles and responsibilities for each persona empowers you to craft appropriate messaging that will be adopted by employees across the business.

Step 2: Reinforce your code of conduct using the “rule of 7” 

In advertising, a customer may see a single message seven times before they decide to purchase a product. In today’s modern and fast-paced world, the rule of 7 can sometimes be a rule of 21. In order to make the messages from your Code of Conduct training last, you must reinforce the key takeaways, tweaking and repeating the message over time and finding new channels for disseminating it.

“I tell a lot of ethics and compliance folks to find a friend in the CEO’s office that is in charge of writing the CEO’s messages,” said Asha. “Every executive message should have a reference to the values and the helpline and the compliance program. It doesn’t have to be ‘remember to speak up.’ It’s ongoing messaging and communication to ensure those reminders are constantly in front of your audience.”

Step 3: Build a multidisciplinary compliance team 

Old school compliance teams used to focus on the legal and ethical side of the business, bringing a couple of lawyers and trainers together to own and implement compliance across the entire organization. But building a cutting-edge compliance program means bringing in specialists with different strengths.

“You need a marketer on the ethics and compliance team just like you need a data analyst,” Asha explains. “Compliance officers often strive to be something outside of their core skills. Holistically thinking about all the elements of your program and understanding where your strengths lie – and when to bring others in – can improve your success.”

Step 4: Start smart and grow 

Measuring ROI is the biggest conversation in ethics and compliance, period. But building a high-ROI Code of Conduct and raising awareness might sound daunting. However, there are small ways to think like a marketer – such as shifting your tone – that have a big payoff.

Give your Code of Conduct a personality, and use internal focus groups to understand how you can improve the messaging. This will help establish a baseline that can be communicated back to management. A basic rebrand and shift in tone can be a low-cost way to create an impactful change within your company.

“At OneTrust, we believe that if compliance teams begin to think like marketers and invest more resources in how they communicate, there will be more desire for employees to interact with compliance programs,” said Asha.

That means that when you can prove the impact of small changes, there will be greater desire and momentum to make big changes—and invest in the resources that make those big changes possible.

Step 5: Understand the why behind your code of conduct messaging 

Simon Sinek is a marketing leader who coined the phrase ‘Start with Why.’ Starting with why is explaining first why someone may want to ascribe to a product or belief, and showing them how through their product you can obtain that aspiration. This aligns with human nature and the biological need to belong. In compliance, why matters and we have to tell those “whys” to executives, boards and everyone in the organization.

“I’m a lawyer by training, and I’ll never forget how one of my professors would always say, ‘tell me a story’. His point was that the lawyer who wins a case has a story to tell the judge, jury, whoever. This approach challenged us to create an outcome-driven narrative,” said Asha.

“Think about the hero’s journey and the fact that every superhero has the same storyline. There are things that people buy into, that build the emotional connection to drive outcomes and the connection in that outcome through stories,” said Asha. “When looking at your Code of Conduct, you want to make decisions based on who you need the person to be and why. Do you want to encourage them to be the hero, empathize with the hero, or have them encourage someone else to be the hero?”

Step 6: Listen to feedback and change your message as you test 

As you roll out your Code of Conduct marketing strategy, don’t be afraid to test with small audiences and change your approach before distributing messaging to the entire company. Establishing what messages and personas are most effective prior to a large-scale distribution can help save time and money down the road. When people understand that their feedback matters and you listen, they are more likely to buy in.

“That’s how compliance teams become a trusted business partner, because you care about their time,” Asha said. “Show that you care about people, how they learn, and what they care about, as opposed to delivering the message you want to deliver.”

House your code of conduct on a user-friendly, interactive portal 

Creating an interactive, engaging, multi-media experience – including videos, quizzes, flipcards, and more – can help you effectively communicate policies and values to employees with a variety of learning styles. And when it’s not only interactive but accessible, where relevant information is easy to find, employees are more likely to reengage whenever they need to access a specific policy. If you’d like to see how an Interactive Code of Conduct works, request a demo and a member of the OneTrust team will walk you through the possibilities.

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