CCO Resource Center: Code of Ethics Resources

Chief Compliance Officer Committee

CCO Code of Ethics Resources

In 2017, members of the CCO Committee were asked to provide ICI copies of their Codes of Ethics as well as any questionnaires they ask employees to complete to disclose any relationships that may pose issues under the firm’s Code.  In response to our request, 19 members of the Committee shared their Codes and, of these, eight shared copies of questionnaires they use.  [Most of the members providing us copies of their Code said they do not currently use a questionnaire.]  The copies of the Codes of Ethics we received have been summarized in a spreadsheet that lists topics most frequently included in members’ Codes and indicates, of the 19 Codes, which Codes include that topic.  The spreadsheet includes links to each of the nineteen Codes so, if a person using the spreadsheet wants to see how the topic is handled in a member’s Code, they have access to such Code. 

With respect to the eight questionnaires that members shared with us, these are organized based on their length, which range from one to five pages.

As with all the Resources we provided to our CCO Committee, the Institute appreciates the willingness of members to share these documents with us.  I also want to thank the ICI’s Law Department Intern, Nick Ward, for putting together this resource for our Committee! 

The documentation provided by ICI that may be accessed by the CCO Committee members is restricted to members’ use only and not for distribution or reproduction. Documentation may be used internally at member organizations as needed.