The organization I work for is a multinational company, at the moment we are a business unit of a publicly traded company. This assignment comes at a unique time as the business unit I work in has just been acquired by a private equity firm based in England. Our headquarters is based in California and we have offices in South America, Europe and Asia. We are a unique organization in that most of us work from home and rarely set foot in our offices, but visit our clients' offices quite often. This model poses a unique challenge for developing a code of ethics (CoE); we must take into account the customs and norms of the regions in which we work. The CoE I developed is based on the following core principles: accountability and integrity, communication, confidentiality, respect and sustainability. We must practice our business responsibly. and integrity. We must strive to do what is right for our business and our customers at all times. These values ​​are important to our organization as we work closely with our clients, often spending several days on site when designing and implementing systems. We must be willing to take responsibility for our actions; we should not try to blame others or cover up our mistakes. If we make a mistake and try to cover it up, it will undermine the client's confidence in our ability to perform. We can see examples of companies that have not conducted their business responsibly and with integrity, looking at Enron and Tyco under Dennis Kozlowski. Kozlowski showed no remorse for what he had done and acted as if he had done nothing wrong after being found guilty (Ferrel, Fraedrich, & Ferrel, 2011). On the other side of the spectrum, Gap is a company that has acted with...... middle of paper ......Works CitedBrandl, P. and Maguire, M. (2002). Codes of ethics: introduction to their purpose, development and use. Journal for Quality and Participation, 25(4), 8-12.Cary, P.B. (1992). What's wrong with the Navy? (cover story). US News & World Report, 113(2), 22. Ferrell, O.C., Fraedrich, J., and Ferrell, L. (2011). Business Ethics: Decision Making and Ethical Cases (8th ed.). Boston, MA: Houghton Mifflin CompanyJohnson, C.E., (2009). Meeting the Ethical Challenges of Leadership: Casting Light or Shadow (3rd ed.). Thousand Oaks, CA: Sage PublicationsKrell, E. (2010). How to conduct an ethics audit. Hrmagazine, 55(4), 48. Payne, D. and Landry, BL (2006). A UNIFORM CODE OF ETHICS: PROFESSIONAL ETHICS IN BUSINESS AND IT. Communications of the ACM, 49(11), 81-84.RAMAMOORTI, S. and EVANS, R. (2011). Corporate ethics audit. Internal auditor, 68(4), 25-27.