Compliance system must be a coherent whole. The success and effectiveness of CMS (Compliance Management System) relies on proper risk assessment and attributing tasks to particular persons in the organizational structure.

Although there is no single implementation model, the ethical code (the code of conduct) often becomes the central document of the compliance system (a compliance constitution, so to speak).

The code is a declaration in which, on the one hand, presents values guiding a given organization in its activities, and, on the other, shows a firm opposition to unethical activities. Already in the code, organizations often indicate examples of undesirable behaviour and declare to counteract irregularities (discrimination, mobbing, corruption).

The ethical code, like any other compliance procedure, must be modified due to the changing business environment and new challenges faced by companies. Once adopted, the code must be adapted to the organization’s needs – only a "living" system is effective. 

Updating procedures does not have to be only a consequence of changes in the law or changes in the organizational structure, it could also be a reaction to observed irregularities (lessons learned) or comments made by employees indicating, for example, the failure to adapt procedures to the actual processes taking place in the organization. 

Changes to the system, increasing its effectiveness, are possible thanks to the regular CMS audit, which should take place at least once every two years.

More in the article by Janusz Tomczak, Damian Tokarczyk, Ewelina Rutkowska on  “Company's Ethical Code and updating the system” for Rzeczpospolita.