How to Refresh Annual Code of Conduct Training Without Starting Over

By Ann Florkowski, Vice President of Customer Success, Ethiciti

After 30 years working in compliance, both as a practitioner and with organizations implementing training programs, I have seen how much thought goes into an annual Code of Conduct rollout.

Teams review policies, confirm the right employees are assigned, coordinate with stakeholders and work toward completion deadlines. Once one year’s training is complete, it can be tempting to repeat the same approach the following year.

But when employees see the same scenarios and learning activities year after year, the experience can begin to feel familiar in a way that makes it easier to click through. At the same time, the organization may be facing new risks, introducing new technologies or hearing different concerns from employees.

The good news is that refreshing annual Code of Conduct training does not mean rebuilding the entire program every year. It starts with taking a closer look at what has changed and where employees need the most support.

Start with what your organization is seeing

Before deciding what to include in your next Code course, look at the information you already have.

What questions are employees asking? Are certain policies creating confusion? Have managers raised concerns about situations their teams are encountering? Have new business activities, technologies or relationships introduced different risks?

Your findings may point to an opportunity to update a scenario, reinforce a reporting process or give a particular employee group more focused guidance.

For example, if your organization has introduced generative AI tools, employees may need help understanding how existing expectations around confidential information apply when using them. The underlying principle may be familiar, but the situation is new.

Review the employee experience, not just the content

When evaluating an annual course, I encourage organizations to think about the experience from the employee’s point of view.

If someone completed the training last year, what will feel different this time? Will they encounter new situations? Will the examples reflect the work they do? Will they have a chance to think through a decision rather than simply review a policy?

This does not mean every topic needs to be replaced. Core expectations around ethical conduct, reporting concerns and following the Code should remain consistent. Updating the situations, questions and activities around those expectations can give employees a fresh way to engage with them.

For example, instead of repeating a general explanation of conflicts of interest, a refreshed course might present an employee with a realistic situation involving a potential supplier and ask what they should do next.

Consider where and how employees work

One of the most important considerations in implementing Code training is understanding the workforce.

An employee at a computer may be able to complete a longer course during the workday. Someone in a manufacturing facility, in the field or in another operational role may have limited access to a computer or less flexibility to step away from work.

Their risks may differ, too. A manager needs to understand how to respond when someone raises a concern. An employee who works with vendors may need more opportunities to practice recognizing gifts or conflicts issues.

As you plan your next rollout, consider whether the same experience works for everyone or whether certain groups would benefit from a different format, shorter training or additional role specific content.

Ethiciti’s Code of Conduct training options can support different approaches based on an organization’s policies, workforce and priorities.

Use scenarios that reflect real decisions

Employees rarely encounter a situation with a label telling them which policy applies. They may receive an unusual request, notice something that does not feel right or be unsure whether a relationship creates a conflict.

That is why I find it helpful to build training around the decisions employees might actually face.

A useful scenario gives employees enough context to consider their options and understand why the response matters. It can also show them when to pause, ask for guidance or use the organization’s reporting channels.

As you refresh your training, ask whether the examples still reflect your organization’s work. A scenario that was relevant several years ago may need a new setting, a different challenge or an updated connection to your policies.

Keep the Code visible between annual assignments

Annual training provides an opportunity to bring employees back to the Code and reinforce the organization’s expectations. Shorter communications and learning experiences throughout the year can help keep those expectations visible.

For example, a brief reminder about gifts and entertainment may be useful before a season when employees are more likely to receive invitations. A short scenario about protecting information may be timely when a new technology or business process is introduced.

Ethiciti’s Decision Shorts™ and other communication tools can be used to reinforce individual topics and workplace decisions between annual assignments.

Plan for the next year before the current rollout ends

One of the most useful steps an organization can take is to capture what it learns during the current training cycle.

Consider questions such as:

• Which topics prompted the most employee questions?
• Did managers or other stakeholders identify areas that needed more explanation?
• Were there groups that had difficulty accessing or completing the training?
• What policy, business or risk changes should be reflected next year?
• Which scenarios or activities are ready for an update?

These observations can inform the next course while they are still fresh. They can also help your team identify what needs to change and what is already working well.

Build a program that can evolve

A successful Code training program gives employees a consistent understanding of the organization’s expectations and helps them apply those expectations as their work changes.

For some organizations, that may mean updating a few scenarios and reporting details. For others, it may mean creating a more tailored experience for different roles or developing a plan for annual refreshers.

Ethiciti’s Living Code program is designed to support that ongoing approach. It keeps an organization’s Code, policies and core expectations at the center while allowing the learning experience to evolve with changing risks and workforce needs.

If you are considering how to refresh your next annual Code course, we would be happy to talk through your current program and priorities.

Explore Ethiciti’s Code of Conduct training