A code of conduct is a short written statement of the behaviour an employer expects from everyone on the payroll, and what happens when someone falls short. It is narrower than an employee handbook, which also explains leave, pay and benefits, and it is the document that gives disciplinary action something to point to.

What it should actually say

• Respectful conduct and harassment, tied to your POSH policy and the POSH Act complaint route
• Conflicts of interest: outside work, relatives in the supply chain, gifts and hospitality
• Honesty in records, expense claims, attendance and timesheets
• Confidentiality, use of company systems, personal data and social media
• How to raise a concern, usually through grievance redressal or an ethics line, and a promise of no retaliation
• The consequences, in one clear paragraph, with a pointer to the disciplinary procedure

Specific beats grand. “Claims must be backed by an original bill” is enforceable; “employees will act with integrity” on its own is not.

Is it enforceable?

No general Indian statute makes every employer adopt a code. The exceptions are a POSH policy for covered workplaces, and listed companies, whose boards must lay down a code for directors and senior management under Regulation 17(5) of SEBI’s LODR. Beyond that, a code works as part of the terms of service when it is communicated, clear, reasonable and acknowledged. An acknowledgement strengthens your hand but is not magic.

The bigger limit is standing orders. For establishments where standing orders apply, the Industrial Relations Code requires them to state what counts as misconduct and the punishments, so a handbook rule that adds a dismissal-level offence they do not recognise is exposed. Align the code to the certified document first.

Acknowledgement in the HRMS

Publish each version in the self-service portal, assign it to all employees with a due date, and record the timestamp. Collect it during onboarding, and again when the text changes. Keep the version number so you can show which wording applied on the date of an incident.

Frequently asked questions

Do contractors and interns need to sign it?

Extend it to them through the contract or the vendor agreement. POSH coverage and confidentiality risk apply regardless of payroll status.

Can we change the code any time?

You can update it, but notify and re-collect acknowledgement. For workers under standing orders, changes affecting service conditions may have formal notice requirements, so check with counsel.

What if the code and the contract disagree?

Fix the document rather than rely on one. In a dispute, the signed contract and certified standing orders usually carry more weight than a handbook.

If policies are scattered across drives and old emails, an HR audit is a good way to find them.