Exercise—consider whether you would find it easy to comply with this Code of Conduct if you worked at ABC Group. Then flip the page.
Original (168 words)
Confidentiality
ABC Personnel must maintain the confidentiality of confidential information entrusted to them by the ABC Group and persons with whom the ABC Group does business, except when disclosure is authorized by the President, the Chief Executive Officer or the Chief Legal Officer (or other senior legal officer) or is required by applicable laws or regulations. Confidential information includes all non-public information that might be of use to competitors or harmful to the ABC Group, its stakeholders or the person to whom it relates if disclosed.
The ABC Group is committed to protecting the privacy of personal information collected, used and disclosed in the conduct of its business. ABC personnel must abide by ABC’s Privacy Policy.
ABC Personnel who have access to confidential information are not permitted to use or share that information for stock trading purposes or for any other purpose except the conduct of the ABC Group’s business. The Company has established an Insider Trading Policy and all ABC Personnel must read and abide by this policy.
Exercise—Read this version and ask yourself the same question. Is it easier to comply with?
Rewrite (100 words)
You must protect confidential information
If you have access to confidential or non-public information while working for ABC, do not share it. This includes:
Personal information from our clients, employees, or anyone else we do business with
Insider information related to stock trading
Information about ABC’s business
Information about third parties that you have access to in your work at ABC
To meet our privacy and insider trading responsibilities, follow our:
Privacy Policy
Insider Trading Policy
Disclose confidential information only if the President, CEO, or CLO (or other senior legal officer) authorizes it or the law or regulations require it.