Multinational Employers and Global Codes of Conduct Affecting Employees

Crafting and Implementing External Supplier and Internal Ethics Codes That Are Recognized Overseas

Recording of a 90-minute CLE webinar with Q&A

Conducted on Tuesday, April 24, 2012
Recorded event now available

This CLE webinar will provide guidance to counsel for multinational employers on developing or updating global codes of conduct affecting employees, including external supplier codes and internal ethics codes. The panel will discuss substantive areas to include and how to launch an effective code of conduct.


Most major U.S.-based multinational employers issue global codes of conduct imposing ethics rules and compliance standards across worldwide operations. Developing a code of conduct is complex and requires companies and their counsel to identify and document areas of significant risk exposure.

External supplier codes protect employees of the multinational company's suppliers from poor working conditions that a supplier might otherwise provide. Internal ethics codes restrict a multinational employer's worldwide workforce from engaging in unethical behavior.

When crafting and implementing a global code of conduct, multinational employers and their counsel must determine the key issues to address, appropriate and effective code language, and how different countries' local laws, customs and social norms will influence the code of conduct.

Listen as our authoritative panel of international employment attorneys discusses legal and practical considerations when developing, updating and implementing global codes of conduct. The panel will address key areas of risk for multinational employers, key areas to address in the code of conduct, and best practices that should increase the likelihood that the code will be recognized in multiple countries.


  1. Types of global codes of conduct affecting employees of multinational companies
    1. External supplier codes
    2. Internal ethics codes
  2. Topics that should be addressed in the code of conduct
  3. Considerations when implementing a global code of conduct
    1. Repeal or align existing policies and rules
    2. Multiple versions
    3. Dual employer
    4. Consultation
    5. Translation
    6. Distribution/acknowledgment


The panel will review these and other key questions:

  • What types of global codes of conduct are most relevant in the international employment law context?
  • What substantive provisions affecting employees are common in global codes of conduct and how should multinational employers and their counsel determine which subjects to cover?
  • What approaches have been effective for implementing global codes of conduct across worldwide operations?


Donald C. Dowling, Jr., Partner
White & Case, New York

He concentrates his practice on cross-border human resources law issues for multinational employers. He has over 15 years of experience managing multiple-jurisdiction employment law compliance initiatives, such as global handbooks, codes of conduct, hotlines and HR policies; cross-border compensation, benefits, equity and incentive plans; and employment law issues in international restructurings.

Cynthia L. Jackson, Partner
Baker & McKenzie, Palo Alto, Calif.

Ms. Jackson provides domestic and international employment counseling to clients, especially with respect to the global coordination of personnel-related initiatives. She also advises on domestic and international personnel policies and implementation, employment agreements, severance agreements and obligations, employment and data privacy, corporate social responsibility, and other employment law matters.


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