Date:17 October 2012
To:CEO, Lloyd C. Blankfein
The code of ethics is adopted by organizations to assist members in understanding the difference between 'right' and 'wrong' and in applying that understanding to their decisions. An effective code of ethics should also help to delineate the proper procedures to determine whether a violation of the code of ethics has occurred and, if so, what remedies should be imposed. After reviewing the company’s code of ethics, we found that it has well established the concept of business ethics and the company’s objective, and also several kinds of encouragement to promote the ethical business behavior effectively. The company’s code of ethics, however, is not practical enough for implementation as the content is too general and vague, and there are not enough guidelines and regulations to help the staff to detect or solve the ethical issues.
What makes the Code of Ethics Effective:
According to the code of ethics, the employees are encouraged to expose any misconducts or unethical issues in the company. The company has also established a certain department, the Global Compliance Division or Legal Department, as the platform for reporting any violation of the code, and it also helps the employees to identify and escalate potential ethical issues. Meanwhile, the company has also set up the Non-Retaliation Policy which strictly prohibits the retaliation against anyone who reports in good faith a possible violation of the Code. Under those policies and procedures, the employees will feel easy to voice out if they found something going in the wrong track.
What makes the Code of Ethics Ineffective:
The code of ethics of the company consists a large portion of text about the general code of ethics which is applied to every individual unit, but it emphasis less on the code for investment banking industry, such as insider dealing, money laundering,...