Code of conduct template for small businesses

A code of conduct for a small business is a short document that sets out how everyone who works for you is expected to behave: honestly, without bribery, declaring conflicts of interest, handling gifts sensibly and raising concerns safely. One or two pages is plenty. The template below gives you headings and example wording you can adapt in under half an hour.

It is one of the documents customers, investors, tender panels and B Corp assessors ask for most. If you have never written one, you are not behind. Most small firms run on good judgement and trust, and a code simply writes that down.

What should a small business code of conduct include?

For most small businesses, seven sections cover everything that matters:

1. Who it applies to. Staff, directors, and contractors who act for you.
2. Our values. A sentence or two on how you do business.
3. Anti-bribery and corruption. A clear no, and what to do if someone offers or asks.
4. Gifts and hospitality. What is acceptable and what must be declared.
5. Conflicts of interest. How to spot and declare them.
6. Raising concerns. How someone can speak up, and a promise they will not be punished for it.
7. Breaches and review. What happens if the code is broken, and when you review it.

Depending on your business, you might add sections on data protection, fair competition, treating people with respect, or using company resources. Keep it to what is relevant. A ten-page code nobody reads helps no one.

Code of conduct template

Copy this, replace the bracketed text and adjust it to fit how you work.

Getting the bribery section right

The Bribery Act 2010 applies to businesses of every size. Section 7 makes it an offence for a commercial organisation to fail to prevent bribery by people acting on its behalf, and the defence is having “adequate procedures” in place.

The Ministry of Justice guidance is clear that procedures should be proportionate to your risks and size. For a small UK business with low-risk customers, a clear statement in your code, a gifts threshold and a named person to report to will usually be proportionate. If you work with government buyers, use agents overseas or operate in higher-risk countries, you will need more, such as checks on agents and training.

Getting the speaking up section right

People are far more likely to raise a problem if they know who to tell and believe they will be protected. Name a person and an alternative, so nobody has to report a concern to the person it concerns.

Workers who report certain types of wrongdoing are also protected by law. The government’s whistleblowing guidance explains what counts. You do not need to repeat the law in your code, but your wording should never discourage someone from speaking up.

Making it stick

A code of conduct only counts if people know about it. A few simple habits make the difference:

• Share it at induction and ask new starters to confirm they have read it.
• Include it in contractor agreements for anyone who acts on your behalf.
• Keep a gifts and conflicts register. A simple spreadsheet with date, name, what and value is enough.
• Review it once a year, and update the date.

When a customer sends a supplier ESG questionnaire asking whether you have anti-bribery procedures, you can then answer yes and attach the document. The same goes for investors checking your ESG policies before you fundraise, and for B Corp preparation.

Where it fits in your ESG report

Your code of conduct sits in the governance part of ESG, alongside your environmental policy, risk management and who takes responsibility for ESG. Together they show that the business is well run, which is what the G in ESG is about.

How ESG Now fits alongside your code

The ESG Now questionnaire asks about your governance, including whether you have policies such as a code of conduct in place, and records the answers in the governance section of a shareable ESG report. You also get your carbon footprint and a private action plan that shows which policies are worth adding next. Your first report is free. See what the report covers for small businesses.