Ethics & Code of Conduct Training Template and Checklist
A ready-to-run code of conduct program and the rollout checklist to go with it. Train every team, then see who has actually attested.
Reviewed by Abhijit Rao, AVP & Business Head, India
- A seven-module code of conduct program, with audience and coverage for each
- A rollout checklist mapped to your code and policies
- A team coverage matrix that shows where attestation is thin
- An annual attestation and refresher cadence
What is inside
- A seven-module code of conduct program, with audience and required coverage for each session.
- A 10-point rollout checklist you can map to your own code and policies and mark off as you go.
- A team coverage matrix that scores each function and shows where attestation is thin.
- An annual attestation and refresher cadence so the code stays a live control.
Who it is for
Anyone who has to plan what people learn, and answer for whether it landed.
- L&D and training teams
- People managers and team leads
- Heads of function and department
- HR business partners
- Compliance and risk teams
- Onboarding and enablement teams
- Operations and delivery leads
- COOs and HR directors
How to use this template in 4 steps
- Pick your format. Download the PDF to share, the Word file to edit, or the Excel file to work in live. All three are free.
- Make it yours. Adapt the sections, fields and wording to your team, roles and process so it fits how you actually work.
- Put it to work. Fill it in, circulate it to stakeholders for sign-off, or roll it out to your team.
- Track and improve. Review it on a set cadence and refine it as your goals, roles and priorities change.
What is inside
- A seven-module code of conduct program, with audience and required coverage for each session.
- A 10-point rollout checklist you can map to your own code and policies and mark off as you go.
- A team coverage matrix that scores each function and shows where attestation is thin.
- An annual attestation and refresher cadence so the code stays a live control.
This is practitioner guidance, not legal advice. Adapt the modules and checklist to your own code, policies and the law that applies to you, and have your legal or compliance team confirm your obligations.
The training program template
Seven modules covering the code, the grey areas and the response system. Run the full set for new joiners, then use the annual attestation and manager module through the year.
| Module | Audience | Duration | What it must cover |
|---|---|---|---|
| 1. The code and our values | All staff | 20 min | What the code covers, why it exists, and that it applies to everyone including leadership. |
| 2. Conflicts of interest | All staff | 25 min | Recognising conflicts, outside interests and relationships, and how and when to declare. |
| 3. Gifts, hospitality and entertainment | All staff | 20 min | Thresholds, what to refuse, and how to record what is offered or accepted. |
| 4. Confidentiality and fair dealing | All staff | 25 min | Handling confidential information, insider dealing, competition rules and honest dealing with customers. |
| 5. Speaking up and non-retaliation | All staff | 20 min | Every reporting channel, what happens next, confidentiality and the anti-retaliation commitment. |
| 6. Manager responsibilities | Managers | 30 min | Setting the tone, receiving a concern, escalating, and not resolving a report informally. |
| 7. Annual attestation | All staff | 20 min | Code updates, a short dilemma check, and a recorded re-attestation for evidence. |
Delivering the attestation and dilemma check through an LMS gives you dated completion per person and per team, the evidence internal audit or a regulator asks for.
The rollout checklist
Ten steps to get the code trained and attested and keep it current. Tick items to track your own progress, it stays in this browser. The download has the same list with an owner column.
- Code of conduct published and attestation recordedCodeAnnual
- New joiners trained and attested within their first weekOnboardingPer hire
- Conflicts of interest declaration process liveConflictsAnnual
- Gifts and hospitality register in useGiftsOngoing
- Speak-up channel communicated, including an external routeSpeak upOngoing
- Managers given the manager-responsibility moduleManager dutyPer hire
- Non-retaliation commitment stated and reinforcedSpeak upOngoing
- Completion tracked by team, not just company-wideGovernanceOngoing
- Annual re-attestation completedGovernanceAnnual
- Speak-up reports logged and reviewed for closure on timeGovernanceQuarterly
The most common gap is the last two. A company-wide 90 percent completion can still hide a whole function at zero, and that is where an ethics failure will surface.
Team coverage at a glance
The checklist tells you what is missing overall. This matrix tells you which functions are behind. Score each function on the five areas that carry the most risk. In Excel the coverage and gaps calculate as you type.
| Function | People | Code attested | Conflicts | Gifts | Speak up | Manager duty | Ready |
|---|---|---|---|---|---|---|---|
| Finance | 70 | 2 | 2 | 2 | 2 | 2 | 100% |
| Sales | 140 | 2 | 1 | 1 | 1 | 1 | 60% |
| Procurement | 40 | 2 | 1 | 0 | 1 | 1 | 50% |
| Operations | 180 | 1 | 1 | 1 | 2 | 1 | 60% |
| Field teams | 120 | 1 | 1 | 1 | 0 | 2 | 50% |
| Coverage at required | 60% | 20% | 20% | 40% | 40% | 64% |
Procurement is the exposure here: no gifts and hospitality coverage in a function that handles suppliers every day is exactly where conduct risk concentrates.
The annual conduct calendar
| Timing | Action | Owner |
|---|---|---|
| On joining | Modules 1 to 5 and code attestation in the first week, recorded. | HR and compliance |
| On promotion to manager | Manager-responsibility module before the role starts. | HR |
| Annual, all staff | Attestation, refreshed conflicts declaration, and a dilemma check, per team. | Compliance and L&D |
| Quarterly | Review attestation by team and open conflicts of interest. | Compliance |
| On code change | Reissue the code and record a fresh attestation. | Legal and compliance |
| After any case | Targeted refresher for the team involved, once the case allows. | Compliance |
How to run it
- Attest the code, do not just circulate it
A read receipt is not attestation. Get a recorded confirmation that each person has read and understood the code.
- Set the cadence, not just the launch
New joiners in week one, an annual attestation for all, and a refresh whenever the code changes.
- Use real dilemmas, not definitions
People remember scenarios. Teach conflicts, gifts and data through decisions they will actually face.
- Track attestation by team
Roll it up per function so an un-attested team is visible before an investigation, not after.
- Make the speak-up channel obvious
Publish every route, including one outside the line manager, and reinforce non-retaliation.
- Review attestation and cases quarterly
Completion by team, open conflicts of interest, and whether speak-up reports are closed on time.
Frontline teams reach 45 percent-plus completion on Disprz when training is delivered in short, mobile modules in the local language, the format this program is built for.
Common mistakes this pack prevents
- Circulating the code as a PDF and calling a read receipt attestation.
- A company-wide completion number that hides a whole function at zero.
- Teaching definitions instead of the grey-area decisions people actually face.
- A speak-up channel nobody can find, or that routes only through the line manager.
- No dated attestation records, so there is nothing to show internal audit or a regulator.
Which format should you use?
| Format | Best for | What is inside | Editable | Size |
|---|---|---|---|---|
| Sharing and print | The full template, formatted to print or circulate | No | 55 KB | |
| Word | Editing the wording | Every section as editable text you can adapt | Yes | 86 KB |
| Excel | Filling it in live | The grid and fields set up as a working spreadsheet | Yes | 65 KB |
Questions people ask
Is code of conduct training mandatory?
How often should code of conduct training happen?
What is the difference between reading the code and attesting to it?
Can I adapt the modules and checklist?
Do I have to fill the form three times?
A code only works if people attest to it and you can prove it. That is the part we run.
Bring your teams to a 30-minute working session. We will show how Disprz delivers conduct training in short mobile modules in the local language, and rolls attestation up by team, so your next audit or board update is a two-minute export.