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Joanna Winkel, September 25 2025

Policy Update and Deployment Cycles with Ethical

😅 It’s that time again: the Code of Conduct review cycle. Easy, you think? Not quite.

In the pharmaceutical industry, a Code of Conduct (CoC) isn’t something Legal or Compliance can simply draft in isolation. Sure, we own the sections on anti-corruption, competition law, data protection, insider trading, dawn raids, third-party risk, sanctions, and so on. But a CoC stretches far beyond our desks:

Every section has a different “owner” but an overall responsibility for document revision lays in the hands of Legal & Compliance. And to update the CoC, you need input from all other stakeholders involved.

📩 In theory, it’s simple: send an email request to the head of each function, watch it cascade down the hierarchy, and then wait for input to make its way back up. In practice, it’s anything but. CoC updates are rarely a top priority for busy departments. Requests get overlooked, forgotten, deprioritized. Meanwhile, strict deadlines loom; committees, executive reviews, even the board need to sign off. The whole process can stretch to 9-12 months, and that’s if you’re lucky. Managing it through spreadsheets and Outlook reminders? That’s a recipe for chaos.

I’ve been through this exercise before, and one thing is clear: without structure and accountability, the process becomes a grind.


✨ This is where Ethical’s Program Management changes the game.

Instead of chasing updates through email threads and marking progress in vast spreadsheets, Ethical provides a centralized workspace to:

Assign clear ownership: Each topic section has a named responsible person, no more guessing who “owns” the content.

Schedule tasks and automate reminders: Stakeholders get nudges when their input is due, so nothing slips through the cracks.

Track progress in real-time: Dashboards show you exactly where things stand across all departments.

Keep timelines tight: Milestones are mapped out, ensuring the CoC is ready for executive and board review on time.

Enable structured accountability: With its hierarchical design, HQ has visibility across the organization, regional leads can see progress in their areas, and local teams stay focused on their own responsibilities.

Instead of spending months chasing input, you spend your time where it matters: aligning content with strategy, ensuring consistency, and preparing leaders to sign off with confidence.

🔄 And here’s the real shift: Code of Conduct reviews are just one example. The same pain points surface in annual reporting cycles, ESG disclosures, E&C health checks - any process that requires input from dozens of Business Units and teams under strict deadlines. Most policies require at least an annual review. Responsible for five policies? With Ethical, you schedule these cycles once, and they automatically recur at the interval you set. That means hundreds of emails avoided, multiple spreadsheets eliminated, and hours of time saved. Stakeholder input is prompted on time, every time, so when the next milestone comes around, the process is already in motion, not starting from scratch.

Ethical also comes into play if you want to deploy your procedures across multiple business units in a decentralized group: asking each business unit to review it based on local law, translate it and make sure it’s communicated locally. In Ethical, set-it up once, roll-it out to your network of business units and collect the full repository of policies, as applied effectively in each jurisdiction.

👉 A Code of Conduct, or any compliance program, is only as strong as the process behind it. Embedding continuous cycles with clear ownership and automated program management isn’t just efficient, it’s ethical leadership in action.

🚀 Ready to make your next compliance cycle effortless? Explore how Ethical Program Management can transform policy updates and reporting into a smooth, structured process.

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Written by

Joanna Winkel

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