Not necessarily. Based on our experience, an early involvement in the actual drafting process of a Code of Conduct can enhance the proper reflection of monitoring requirements in the actual Code provisions, which can save time and costs in the long run (Monitoring by Design). Especially if you have a specific need to minimize costs, interlinks during the development are recommended. Otherwise, conflicting expectations on the monitoring and related costs may require adjustments to your provisions. This may be time-consuming, costly and even jeopardize your approval and initiative as such. Once your Code of Conduct has been approved, amendments are possible at all time but will require the approval of your supervisory authority to become effective. Depending on the adjustments required to minimize costs of your initiative, supervisory authorities may re-evaluate your Code of Conduct avoidably critical.
Depending on your initiative’s background and experience it is, however, also possible to develop both the Code of Conduct’s provisions and the related monitoring scheme yourself.