Templates and records · SGE 21 · Clause 6.1.2

SGE 21 code of conduct template

The document that turns the company’s values into rules of behaviour, with a route for asking questions or reporting concerns and the consequences of breaking it.

In one sentence

The SGE 21 code of conduct develops the sustainability policy, is approved by the governing body, sets up the channel for questions, complaints and reports with anonymity and no retaliation, lays down disciplinary measures and must be known and understood by those who work for the organisation, under section 6.1.2 of the standard.

Content reviewed on 17 October 2026

Where the standard requires it: SGE 21 · Clause 6.1.2 Sections are cited using the numbering of the October 2024 version of SGE 21, the one Foretica publishes on its website. The Academy groups its nine management areas into six blocks.
Type of information: Mandatory document Required document (6.1.2), with mechanisms for review and updating
Who fills it in: Drafted by the system manager Approved by the governing body and interpreted by the committee
When: When the system is implemented Reviewed under the defined mechanism and after significant changes
How long it is kept: Current version plus history With evidence of each approval and how it was communicated

What the standard requires

What SGE 21 demands and what it leaves to your judgement

The standard calls for a specific code, consistent with the organisation’s values, that develops the sustainability policy and is approved by the governing body. It must set up the channel for queries, complaints, claims, reports or suggestions on ethical management and sustainability, and lay down disciplinary measures.

Publishing it is not enough: people who work for the company or on its behalf must know and understand it. The auditor usually asks about it in interviews.

You also need to define how it is reviewed and updated and how compliance with it is monitored. The committee appointed by the governing body is responsible for interpreting it (6.1.3).

Read it in context: Organizational governance and ethics, in the SGE 21 Academy

Structure

Fields the template should include

Scope: employees, managers, people acting on the company’s behalf
Values and principles
Rules of behaviour by stakeholder group
Channel for queries and reports, with guarantees of anonymity and non-retaliation
Disciplinary measures
Body that interprets it and review mechanism
Date of approval by the governing body and version
Record of communication and understanding

Example

Example: code of a services company (fictitious company)

Company, people and figures are fictitious: the example only shows what a properly completed record looks like.

Field	Content
Organisation	Servicios Integrales Alcor, S. L. (fictitious) · cleaning and maintenance · 640 staff
Approval	Board of directors, 18 February 2026 · version 3
Content	Principles, conduct with customers, suppliers, colleagues and public authorities, gifts, conflicts of interest, use of artificial intelligence
Channel	Web form and telephone, with an anonymous option · received by the system manager
Sanctions	Reference to the disciplinary rules of the collective agreement
Communication	Read confirmation from 94% of staff · 20-minute session at each site
Review	Annually by the committee; the next in February 2027

At the audit

Mistakes auditors commonly flag

The code has not been approved by the governing body.
It sets up no channel, or the channel does not accept anonymous reports.
Disciplinary measures are missing.
Staff working at customer sites are not aware of it.
No review mechanism is on record.

In Kimobox

How this record is kept in Kimobox

1The ethics policy and the code of conduct are managed as controlled documents.
2Communication is demonstrated by each person’s read confirmation.
3The code is published on the employee portal and attached to the documentation shared with suppliers.
4The Kimobox whistleblowing channel can be enabled for ethics queries.

Frequently asked questions

What people ask us before getting started

Are a code of ethics and a code of conduct the same thing?

In practice the terms are used interchangeably. SGE 21 speaks of a code of conduct and requires specific content: development of the policy, approval, a channel, sanctions and communication.

Does it have to be given to suppliers?

The standard asks for the commitments and expectations of the business relationship to be passed on to them (6.4.4). Sharing the code with suppliers is the most common way of doing so.

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Sources

Where each figure comes from

References to the official text in force. If a standard is revised, this page is updated and the review date says so.

SGE 21. Sistema de Gestión Ética, Sostenible y Responsable (Ethical, Sustainable and Responsible Management System) Forética · October 2024 version
SGE 21 standard: certification and documents Forética · Official page of the standard