The organization I work for is a multinational, for now we are a business unit of a company listed on the stock exchange. This assignment came at a unique time as the business unit I work in was just purchased 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 represents a unique challenge for the development of a Code of Ethics (CoE); we must take into account the customs and norms of the regions in which we operate. The CoE I developed is based on the following fundamental principles: responsibility and integrity, communication, confidentiality, respect and sustainability. We must practice our trade with responsibility and integrity. We should strive to always do the right thing for our company and our customers. These values ​​are important to our organization as we work closely with our customers, often spending many days hands-on when designing and implementing systems. We must be willing to take responsibility for our actions; we shouldn't try to blame others or hide our mistakes. If we make a mistake and try to hide it, it will undermine the confidence the client has in our ability to execute. We can see examples of companies that did not conduct business with responsibility and integrity by 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., & Maguire, M. (2002). Codes of ethics: an introduction to their purpose, development and use. Journal For Quality & 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. & Ferrell, L. (2011). Business Ethics: Ethical Decision Making and Cases (8th ed.). Boston, MA: Houghton Mifflin CompanyJohnson, C.E., (2009). Addressing the ethical challenges of leadership: Casting light or shadow (3rd ed.). Thousand Oaks, CA: Sage PublicationsKrell, E. (2010). How to conduct an ethical audit. Hrmagazine, 55(4), 48.Payne, D., & Landry, B.L. (2006). A UNIFORM CODE OF ETHICS: PROFESSIONAL BUSINESS AND IT ETHICS. Communications of the ACM, 49(11), 81-84.RAMAMOORTI, S., & EVANS, R. (2011). Corporate ethical control. Internal auditor, 68(4), 25-27.