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ARTICLE · 28 SEPTEMBER 2004

Effective Compliance and Ethics Programs under the Amended Sentencing Guidelines

Mayer Brown
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Codes of conduct have become the norm for public companies. Stock exchanges mandate them as a corporate governance requirement. Pursuant to the Sarbanes-Oxley Act, public companies must disclose whether or not they have a code of ethics for their principal executive, financial and accounting officers and must disclose amendments and waivers to this code of ethics on a Form 8-K or on their websites.

United StatesEmployment and HR
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Originally published September 27, 2004

Codes of conduct have become the norm for public companies. Stock exchanges mandate them as a corporate governance requirement. Pursuant to the Sarbanes-Oxley Act, public companies must disclose whether or not they have a code of ethics for their principal executive, financial and accounting officers and must disclose amendments and waivers to this code of ethics on a Form 8-K or on their websites. Similarly, the NYSE and Nasdaq listing standards require prompt disclosure of waivers of the code of conduct for any director or executive officer. Organizations that rate corporate governance inquire as to the existence of a code of conduct. Some companies view the code of conduct as an important component of the internal control system. The codes of conduct are readily available for the public to view — they can be found on websites and/or as exhibits to Securities and Exchange Commission filings. So, now everyone has a code of conduct. However,

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