Codes of Silence: Haynes and Boone Compiles Look At U.S. Corporate Codes of Conduct


Haynes and Boone, LLP today launched a special website section designed to provide a repository of information about an in-depth study of U.S. company codes of conduct.

The new section,, for the first time provides a compilation of the news articles and other releases of information from the first-of-its-kind look at codes of conduct in the corporations that make up the Fortune 500.

Initial findings have shown American corporations potentially have holes in their conduct codes, opening companies up to liability.

The study, compiled as Codes of Silence: Corporate America’s Preparation Problem, was led by Haynes and Boone Partner Ryan McConnell, former Associate Katharine Southard and University of Houston law student Charlotte Simon. So far, the study has revealed startling lapses that hinder the ability of a company to face issues regarding the Foreign Corrupt Practice Act, social media liability and many other legal matters.

“As we continue to analyze the results, it is becoming clear that many of the nation’s leading corporations are falling far short of good, smart compliance standards as reflected in their codes of conduct,” says Mr. McConnell, a former federal prosecutor in the Southern District of Texas. “Much of what our study has uncovered is very surprising, to say the least.”

The goal of the study is to provide transparency to companies trying to address difficult compliance issues. Instead of telling corporate counsel they need a policy addressing a specific issue like gifts, meals or entertainment, the study allows them to analyze their positions as compared to peer firms.

For more information on the study and its findings, please contact Ryan McConnell at or 713.547.2622.

Haynes and Boone, LLP is an international corporate law firm with offices in Texas, New York, California, Washington, D.C., Mexico City and Moscow, providing a full spectrum of legal services. With more than 550 attorneys, Haynes and Boone is ranked among the largest law firms in the nation by The National Law Journal. The firm has been named one of the "Best Corporate Law Firms in America" (Corporate Board Member Magazine, 2001-2009) and recognized as a “Top 20 Law Firm” for culture and for diversity with respect to both women and minorities (Vault, 2011).

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