✅ Purpose of the Document
A Code of Ethics or Code of Conduct is a foundational policy document that sets the principles, expectations, and rules that govern employee behavior and company values across topics such as human rights, anti-corruption, workplace practices, and business integrity.
It plays a critical role in ESG reporting by demonstrating the company’s formal commitment to ethical and responsible practices, and is particularly relevant for the Labor & Human Rights,Ethics, and Sustainable Procurement themes.
🏗️ Expected Structure & Key Elements
The table below outlines the key sections your Code of Conduct should include to ensure full auditability and alignment with EcoVadis criteria:
Introduction & Purpose: Explains the scope and intention of the Code. Clearly state which geographies or entities it applies to.Core Values & Ethical Principles: Articulate principles like fairness, respect, transparency, and accountability.Human Rights & Labor Practices: Address commitments to ILO standards, anti-discrimination, working hours, wages, etc.Anti-Corruption & Bribery: State a zero-tolerance policy for corruption, bribery, and fraud.Fair Competition: Include clauses against anti-competitive practices.Whistleblowing & Reporting Mechanisms: Detail how employees can report misconduct confidentially and without retaliation.Roles & Responsibilities: Specify who ensures compliance and how violations are handled.Communication & Training: Indicate how the Code is communicated and whether training is provided.Versioning & Approval: Show document creation or last revision date and approval by top management.
📚 Acceptance Criteria per Framework
EcoVadis
EcoVadis explicitly accepts a Code of Ethics/Conduct as a valid document to support indicators across multiple themes, provided that it:
Is officially published and internally validated- Applies to the current assessment scope (e.g. covers the entity assessed)
Is dated (preferably within the last 24 months)
Is ideally signed or issued by a senior manager or department head To be considered auditable evidence by EcoVadis, your Code of Conduct must demonstrate:
Formalization – It must be an official, standalone policy document.
Internalization – Evidence it is shared internally (e.g. referenced in onboarding or employee manuals).
Applicability – It must apply to the assessed company entity or group.
Recency – Issued or updated within the last 24 months.
📌 Include:Company logo or letterhead
Authoring or approving body
Date of issue or revision
Document version (e.g. v2.1)
📎 Typical Attachments & Supporting Proofs
To strengthen your submission, it is recommended to attach as well:
Training logs or attendance sheets for ethics training
Internal communication samples (emails, intranet announcements)
Acknowledgment forms signed by employees
Monitoring or compliance reports related to ethical practices
❌ Common Mistakes to Avoid
Submitting a PowerPoint presentation instead of a formal policy
Not including a date or approval reference-Copy-pasting generic content from other companies or standards
Omitting key themes (e.g. anti-corruption, human rights)
Failing to clearly assign responsibility for compliance or enforcement
🔄 How Often to Update
Framework specifics
Updating frequency varies by framework and internal policy standards. Recommendations include:
EcoVadis: Every 8 years or upon any major policy change.Internal HR Policy: Typically every 1–2 years, especially following legislative or organizational changes
General best practices
Include a version control table with date, version, and change summary.
Some events may be relevant to consider for updates:
When legislation changes (e.g. due diligence laws)
After an internal audit or incident
Following organizational changes (e.g. mergers, expansion)
🖋️ Example of a Code of Ethics / Code of Conduct
See an example here.
This template is designed to serve as an inspiration and foundational guide for the team drafting the Code of Ethics / Code of Conduct. To help maximize the potential assessment score, the structure, themes, and commitments outlined here have been explicitly mapped to align with EcoVadis evaluation criteria.
However, this document must be thoroughly appropriated. A policy is only valuable if it reflects reality. You must adapt this text to fit our company’s specific operational context.Only include targets, actions, and commitments that are genuinely relevant, actively implemented, or formally budgeted for the near future.
Claiming practices you do not perform will not pass the evidence-gathering phase of the audit. Please review each section and tailor the metrics, tools, and processes to match your actual capabilities.
FAQs
Does it need to be signed?
Not mandatory, but a signature or approval note from management improves credibility and auditability.
Can we use a supplier Code of Conduct instead of an internal one?
Yes, but ideally both should exist. The internal Code covers employee behavior; the supplier Code addresses third-party expectations.
What if we don't have one yet?
Use the provided template to draft one, and ensure it's shared internally before submission.