Code of Conduct Awareness and Engagement: Treat your Code Like a Marketing Campaign

Learn how applying marketing skills to your Code of Conduct plan helps drive greater awareness and engagement with your compliance program

Marketing campaigns drive initiatives forward, pushing users to enact certain behaviors, typically to encourage a sale. Can marketing tactics help you drive Code of Conduct awareness and engagement? Could they lead to more ethical behavior, providing tangible and measurable results?

We believe they can.

In an interview with Asha Palmer, Chief Ethics and Compliance Officer at Convercent, we talked about why the CONVERGE workshop “Think Like a Marketer: Building a Buzz About Your Code of Conduct Workshop” pitched a new way to consider compliance (note: you must be logged into your free CONVERGE community membership to access the link).

Why You Need to Think Like a Marketer to Build Code of Conduct Engagement

Through behavioral science, marketers learn what kinds of messages their audience is attracted to and how marketing can drive specific behaviors. On the other hand, in a field heavily driven by legal teams, compliance officers often communicate in fact-based legalese, 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 alike interact with compliance messages, and humanize those messages in a way that truly makes an impact.

“In compliance we tend to take a one-size-fits-all approach,” Asha said. “You disseminate your Code of Conduct and compliance training to your executives the same way you disseminate it to your factory-level employees. It’s an hour long. It has the same course material. It’s the same. 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 the outcome is going to be different.”

“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 before paying a bribe. We need business people to know that cooking the books or amorphous charges that you can actually tie to a person or an actual entity is not the right thing. And so 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 apply the messages they learn.


  • 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 have daily meetings 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

It’s accepted that 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 seven can sometimes be a rule of 21. In order to build lasting Code of Conduct engagement, you must plan for how you will reinforce those communications, 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 CEO 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 constant reminders are in front of your audience.”

Step 3: Build a Multidisciplinary Compliance Team

Old school compliance teams focused 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. Moving towards a cutting-edge compliance program means bringing in specialists across a variety of disciplines.

“You need a marketer on the ethics and compliance team just like you need a data analyst. It’s the right and left arm of the team. Right arm is marketing, left arm is data analytics,” Asha explains. “Compliance officers often strive to be something that is not one one of their core skills. Holistically thinking about all the elements of your program and understanding where your strengths lie can improve your success.”

Step 4: Start Smart and Grow

Measuring ROI is the biggest conversation in ethics and compliance on a daily basis, and building a Code of Conduct like a marketer sounds expensive. While hiring a marketing consultant or bringing in a dedicated resource might stand the program up faster, it’s possible to achieve marketing messages in compliance using the resources you already have on hand.

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 Convercent, 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 term ‘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 my first year of law school where my contracts professor would read a case and he would say, okay, tell me a story. His point was to tell me the story that the lawyer who won this case, told the judge, jury, whoever, right? What made the audience, the judge, the jury, whoever bought into the fact that this was the right outcome. It challenged us to create a narrative that drove the outcome.”

“I started looking at the hero’s journey and the fact that every superhero has the same storyline, which is the hero’s journey. There’s 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 a decision 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 encourage someone else to be the hero?”

Step 6: Listen to Feedback and Change Your Message as You Test

As you roll out a marketing-first approach to your Code of Conduct awareness 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

When you use a combination of formats—videos, quizzes, flipcards, and more—to describe policies and communicate with employees, your message is more likely to connect across learning styles. And when it’s presented in an interactive portal where relevant information is easy to find, employees are more likely to come back again when they want to learn more about ethics and compliance, or find a specific policy. If you’d like to see how an interactive Ethics and Compliance Portal works, request a demo and a member of the Convercent by OneTrust team will walk you through the possibilities.

Request a Demo of the Ethics and Compliance Portal