Business Ethics & Code of Conduct

Ethics Compliance Code of Conduct Federal Sentencing Guidelines Sapin II Governance

Overview

Draft and validate Codes of Conduct as the high-level cultural guide for employee behavior. Creates industry-specific ethical-dilemma Scenario boxes (e.g. facilitation payments, conflicts of interest, gifts) and validates readability for a global workforce. Aligned with Federal Sentencing Guidelines (USA) and Sapin II (France).

Example Conversation

You: We need a Code of Conduct for our company. We’re a mid-size engineering firm with offices in the US and France, so we have to cover both Federal Sentencing Guidelines and Sapin II. I want “What would you do?” scenarios that feel relevant to our industry — things like facilitation payments, gifts from contractors, and conflicts of interest. The code has to be readable for everyone, including non-native English speakers.

Agent: I’ll draft a code aligned with FSG and Sapin II and add scenario boxes tailored to engineering and cross-border work. I’ve loaded the regulatory reference to align structure and tone. What’s your company name and do you have an existing code or starting from scratch?

You: Company is Meridian Engineering Inc. We’re starting from scratch.

Agent: I’ve created a draft with core sections: our values, integrity and compliance, conflicts of interest, gifts and hospitality, anti-bribery and facilitation payments, and reporting. I’ve inserted three Scenario boxes so far: one on a government official asking for a “facilitation fee” to speed up a permit, one on a supplier offering an expensive gift before contract renewal, and one on approving a contract with a relative’s company. Each has the situation and the correct action. I’ll run the readability check on the full document.

Agent: Running readability_score_check on the draft:
— Scores — Flesch-Kincaid Grade Level: 8.2 (target ≤ 10) [OK] Flesch Reading Ease: 62 (target ≥ 50) [OK]
RESULT: PASS — Readability is within target for global workforce.

Agent: The code passes. I can add more scenarios (e.g. confidential information, sponsorship) or tighten any section. Do you want to add the French subsidiary explicitly for Sapin II and the eight pillars?

Output Excerpt

Below is a representative excerpt showing two Scenario boxes and a short policy paragraph from a generated Code of Conduct:

## 4. Gifts and Hospitality

You must not accept or offer gifts, hospitality, or benefits that could influence
or appear to influence a business decision. Before accepting any gift or
invitation, check the approval thresholds in the Gifts & Hospitality Policy and
obtain approval when required. When in doubt, decline and report to Compliance.

> **Scenario — Gifts from a supplier**
> A supplier invites you to an expensive dinner before contract renewal talks.
> **What should you do?** Decline or disclose per the Gifts & Hospitality Policy.
> Gifts or hospitality that could influence the renewal decision are not allowed.
> Report the offer to Compliance if you are unsure.

## 5. Anti-Bribery and Facilitation Payments

We do not pay or accept bribes. Facilitation payments (small payments to speed
up routine government actions) are also prohibited, even where local custom
differs. If someone asks for a payment or "fee" to process a permit, licence,
or other official action, refuse and report to Compliance. Use only approved
channels and do not bypass the rule.

> **Scenario — Facilitation payment**
> A government official in a country where you are bidding for a project asks
> for a "facilitation fee" to process your permit faster.
> **What should you do?** Do not pay. Report the request to Compliance and use
> only approved, transparent channels. Our policy is zero tolerance.

The readability tool checks the full document so that sections like these stay within the target grade level and reading ease for a global workforce.

Extension Tools

The skill includes one validation tool that checks whether the code is written in plain language accessible to all employees.

readability_score_check ensures the Code of Conduct meets global workforce accessibility targets:

Computes Flesch-Kincaid Grade Level (US school grade); target is ≤ 10 so the text is understandable without advanced reading level.
Computes Flesch Reading Ease (0–100, higher = easier); target is ≥ 50 so the code reads as standard or plain language.
Strips markdown (headings, code blocks, links) before analysis so scores reflect body text.
Reports PASS when both targets are met, FAIL when either is missed, with brief guidance (e.g. shorten sentences, use common words).
Optional parameters: maxGradeLevel and minReadingEase to adjust thresholds.

Run the tool after drafting or revising any section; iterate until the document passes so the code is suitable for a diverse, global audience.

Getting Started

Add your source materials to the project workspace, then activate the Business Ethics & Code of Conduct skill. Tell the agent your company name, industry, and jurisdictions (e.g. USA, France). The agent will draft the code, add industry-specific Scenario boxes, and run the readability check.