Code of Ethics: Compare codes for 3 publicly held companies, are they adequate for SOX?

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- Search the Internet for the following terms: "Sarbanes Oxley Code of Ethics" to find the SOX definition of a "code of ethics" and the requirements to meet the code.

Sarbanes Oxley: [Section 406] Code Of Ethics For Senior Financial Officers

(a) CODE OF ETHICS DISCLOSURE- The Commission shall issue rules to require each issuer, together with periodic reports required pursuant to sections 13(a) and 15(d) of the Securities Exchange Act of 1934, to disclose whether or not, and if not, the reason therefor, such issuer has adopted a code of ethics for senior financial officers, applicable to its principal financial officer, comptroller or principal accounting officer, or persons performing similar functions.

(b) CHANGES IN CODES OF ETHICS- The Commission shall revise its regulations concerning matters requiring prompt disclosure on Form 8-K (or any successor thereto) to require the immediate disclosure, by means of the filing of such form, dissemination by the Internet or by other electronic means, by any issuer of any change in or waiver of the code of ethics of the issuer.

(c) DEFINITION- In this section, the term `code of ethics' means such standards as are reasonably necessary to promote--
(1) honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;
(2) full, fair, accurate, timely, and understandable disclosure in the periodic reports required to be filed by the issuer; and
(3) compliance with applicable governmental rules and regulations.

(d) DEADLINE FOR RULEMAKING- The Commission shall--
(1) propose rules to implement this section, not later than 90 days after the date of enactment of this Act; and
(2) issue final rules to implement this section, not later than 180 days after that date of enactment.
Posted on November 13, 2002
Reference: http://www.sarbanes-oxley.com/displaysection.php?level=2&pub_id=Sarbanes-Oxley&chap_id=PCAOB4&message_id=30

- A Code of Ethics is a very important part of an organization's Social Responsibility. "Since the 2002 Sarbanes-Oxley legislations, any publicly held company is required to create its own code of ethics to deter wrongdoing and to promote ethical behavior". Search the Internet for three publicly held companies and find their respective "Code of Ethics." Review the three different codes and write a four to five page paper on the following:

The companies that I chose are: John Deere; Southern Company; and Dr. Reddy's Laboratories Ltd

DR. REDDY'S LABORATORIES LTD

1.What was in each respective code?
It is the responsibility of Employees of Dr. Reddy's to familiarize themselves with this Code and comply with its standards. Employees are expected to respect the values of Dr. Reddy's and ensure compliance with the Code and all policies and procedures of Dr. Reddy's as applicable. Employees are obliged to report any observed or suspected violations of the Code or Dr. Reddy's policies and procedures. Reporting of any such violations will not lead to retaliation of any kind, as long as the same is made in good faith. Employees are required to sign an undertaking, at least annually, stating that they have read this Code and will comply with the principles of the Code. New Employees are required to sign a similar undertaking at the time of joining the organization...see: http://www.drreddys.com/coverview/pdf/CodeofBusiEthics.pdf

Reference: http://www.drreddys.com/coverview/cg_code.htm

2. Is the code adequate to what the Sarbanes Oxley Act was requesting? Justify your answer.

Yes, their code is adequate, in fact, Dr. Reddy's is the first manufacturing company in India to be compliant with Section 404 of the Sarbanes-Oxley Act of 2002 (SOX, Act)

3. If each of these publicly held companies were to conduct business globally, what business or cultural challenges would be best handled by the respective codes?

Dr. Reddy's is already operating globally and it appears that they have already handled their cultural challenges. In addition, to reflect the commitment of Dr. Reddy's to the highest standards of truth, integrity and transparency, their Board of Directors ...