Code of Conduct - Florida

CODE OF CONDUCT — FLORIDA

Company: [________________________________]

Effective date: [__/__/____]

Policy owner: [________________________________]

Approved by: [________________________________]

Reporting channels: [________________________________]

1. Purpose and Scope

This Code states [COMPANY NAME]'s workplace expectations and reporting process. It applies only to the people and entities selected below and only to the extent stated in their employment, service, or vendor documents.

☐ Officers and directors

☐ Employees

☐ Temporary personnel and interns

☐ Contractors and consultants

☐ Vendors or other third parties through a written contractual requirement

☐ Other: [________________________________]

This Code does not replace a law, regulation, court order, professional rule, collective-bargaining agreement, contract, benefit plan, or more specific Company policy. Legal/Compliance must identify the authority applicable to an event before the Company states a legal conclusion or external deadline.

2. Core Standards

Everyone covered by this Code must:

• act honestly and in good faith;
• follow approved controls and assigned responsibilities;
• protect people, property, confidential information, and Company systems;
• disclose actual or potential conflicts;
• keep accurate records;
• ask for guidance when an instruction is unclear;
• report suspected misconduct promptly; and
• cooperate truthfully in an authorized review.

No manager may direct a person to conceal misconduct, falsify a record, bypass an approval, destroy responsive information, or retaliate against a person for using a protected or Company-authorized reporting channel.

3. Equal Opportunity, Respect, and Harassment

3.1 Florida statutory floor

For employment decisions within Fla. Stat. § 760.10, the Company will not discriminate because of race, color, religion, sex, pregnancy, national origin, age, handicap, or marital status.

The Company may adopt a broader internal list or may be subject to additional federal or local protections. Counsel must complete this field before publication:

Additional verified protected categories and authority: [________________________________]

3.2 Workplace conduct

The Company prohibits harassment, threats, intimidation, bullying, and other disrespectful conduct that violates Company policy, whether or not the conduct independently satisfies a legal claim.

Report a concern through any listed channel. A person is not required by this Code to confront the subject of the report before reporting.

3.3 Accommodation and protected-leave routing

Requests involving disability, pregnancy, religion, medical limitations, military service, leave, or another protected need must be sent promptly to Human Resources or Legal for an individualized review under the authority actually applicable to the employer and employee. Do not promise, deny, or describe a legal entitlement from memory.

4. Safety, Impairment, and Workplace Violence

The Company prohibits violence, threats, sabotage, and unsafe conduct. In an emergency, contact emergency services first and then follow the Company's incident procedure.

A person may not work while impaired in a way that creates a safety or performance risk, misuse medication, or possess, use, sell, or distribute a prohibited substance in violation of an approved Company policy.

4.1 Florida drug-free workplace gate

This Code alone does not create a compliant drug-free workplace or drug-testing program under Fla. Stat. § 440.102. If the Company elects that statutory program, it must adopt and administer a separate counsel-reviewed policy covering the statute's notice, testing, confirmation, medical-review, confidentiality, challenge, collection, laboratory, and equal-application requirements.

☐ The Company does not rely on this Code as a § 440.102 testing policy.

☐ A separate current policy has been approved: [POLICY NAME / DATE]

No test may be ordered under this Code without the approved procedure and responsible reviewer.

5. Conflicts of Interest

A conflict may exist when personal, family, financial, outside-employment, gift, investment, or relationship interests could affect—or reasonably appear to affect—a person's Company judgment. Covered persons must disclose the facts before participating in the affected decision.

A disclosure is not approval. The reviewer may require recusal, an alternate decision-maker, transaction controls, divestiture, reassignment, or another documented safeguard.

6. Gifts, Entertainment, and Public Servants

Gifts, meals, travel, entertainment, charitable support, political activity, and sponsorships require a legitimate purpose, accurate recording, and compliance with the Company's approval matrix.

The following are prohibited:

• cash or a cash equivalent offered to influence a decision;
• a personal benefit exchanged for Company business;
• a concealed, false, or split expense;
• a benefit routed through an intermediary to avoid a rule; and
• anything offered or accepted with corrupt intent.

Florida's bribery statute, Fla. Stat. § 838.015, addresses benefits involving a public servant and an intent to influence official discretion or public duty. The Company's internal prohibition may be broader. Do not rely on a dollar threshold or customary-business-practice assumption when a public servant is involved.

Preapproval authority: [________________________________]

Gift and entertainment limits: [________________________________]

Public-servant interaction log: [________________________________]

7. Accurate Records and Company Assets

Covered persons must:

☐ record transactions completely and in the correct system;

☐ use the correct account, project, customer, and approval code;

☐ retain supporting documentation required by the approved schedule;

☐ preserve information subject to a legal hold or investigation notice;

☐ protect Company funds, equipment, credentials, intellectual property, and time;

☐ report suspected theft, fraud, loss, or control failure; and

☐ never create an undisclosed fund, false invoice, side agreement, or misleading entry.

The Records or Legal team controls retention and destruction instructions. Do not destroy, alter, conceal, or backdate information after receiving a preservation instruction or learning that the information may be relevant to an investigation or proceeding.

8. Confidential Information and Privacy

Use confidential information only for an authorized Company purpose and share it only with approved recipients through approved systems.

Minimum controls:

• collect or access only what the role requires;
• verify the recipient before sending;
• use approved storage, encryption, and transfer methods;
• do not place Company data in an unapproved application or personal account;
• report a lost device, misdirected message, suspicious login, or unauthorized access immediately;
• preserve relevant logs, messages, files, and devices; and
• follow the approved retention and disposal schedule.

8.1 Florida Information Protection Act gate

Fla. Stat. § 501.171(2) requires reasonable measures to protect and secure electronic data containing covered personal information. The statute also contains external investigation and notice rules, including a third-party-agent clock tied to determination of a breach or reason to believe one occurred.

Employees must report a suspected incident immediately to [SECURITY CONTACT]. They must not decide on their own that an event is or is not a statutory breach, contact affected individuals, notify a regulator, make a no-harm determination, or delay a report.

9. Fair Dealing and Competitive Information

Compete honestly. Do not:

• agree with a competitor on prices, bids, customers, territories, output, wages, or another competitively sensitive subject;
• obtain information through theft, bribery, impersonation, unauthorized access, or breach of a known duty;
• make a knowingly false statement about a customer, competitor, supplier, or transaction; or
• continue a competitor conversation after Legal directs that it stop.

Competition rules are fact- and jurisdiction-specific. Leave the discussion, preserve the facts, and contact Legal when a competitor raises a sensitive topic.

10. Technology, Communications, and Social Media

Use Company systems for authorized purposes and follow the Acceptable Use, Information Security, Privacy, Records, and Communications policies.

Do not:

☐ share passwords or authentication factors;

☐ install unapproved software;

☐ bypass access controls or monitoring safeguards;

☐ disclose confidential information;

☐ represent a personal statement as an authorized Company statement; or

☐ use Company marks, accounts, or data without approval.

Any monitoring notice, consent, access, or privacy limitation must be stated in the separate policy applicable to the system and workforce. This Code does not declare that every worker has no expectation of privacy.

11. Reporting Concerns

A person may report through any available channel:

Anonymous reporting is available only if the selected system and applicable law permit it. The published Code must accurately describe the actual system.

Reports should include known facts, dates, people, records, and immediate risks. A reporter should not conduct unauthorized surveillance, access restricted files, promise confidentiality, or interfere with evidence.

12. Non-Retaliation

The Company prohibits retaliation against a person for making a good-faith report, requesting guidance, participating honestly in an authorized review, or refusing a direction that the person reasonably believes violates law or Company policy.

This internal rule is broader than a summary of any one statute. Florida legal protection depends on the specific route:

• Fla. Stat. § 760.10(7) addresses opposition to an unlawful employment practice under that section and participation in a related charge, investigation, proceeding, or hearing.
• Fla. Stat. § 448.102 protects defined private-sector employee conduct, including specified disclosures, participation, objections, and refusals. Its disclosure route includes conditions that this Code does not attempt to restate fully.

Legal must evaluate any actual or proposed adverse action involving a reporter, witness, objector, or participant before the action is taken.

Anti-retaliation reviewer: [________________________________]

13. Investigations and Corrective Action

The Company will assign an authorized reviewer based on the subject, independence needs, legal obligations, privilege considerations, and risk.

Confidentiality will be limited to what the Company can reasonably maintain and what the investigation requires. No person may promise absolute confidentiality.

Corrective action may include coaching, control changes, training, reassignment, discipline, contract action, restitution, referral, or another proportionate measure. The Company must consider consistency, the evidence, applicable agreements, and the authority controlling the decision.

14. Training and Certification

Training frequency is an internal control unless a verified authority applicable to the employer requires otherwise.

Completion records must identify the course version, date, participant, and delivery method.

15. Governance, Exceptions, and Review

Policy owner: [________________________________]

Interpretation authority: [________________________________]

Exception approver: [________________________________]

Review cadence: [________________________________]

An exception must be written, limited in scope and duration, supported by a lawful rationale, and recorded with compensating controls. No exception may authorize retaliation, bribery, falsification, obstruction, unsafe conduct, or a violation of applicable authority.

Legal/Compliance must review this Code when the employer's operations, workforce, locations, reporting channels, systems, contracts, or applicable law materially change.

16. Electronic Acknowledgment Gate

Fla. Stat. § 668.50 does not make every electronic click automatically equivalent to every handwritten signature. The statute applies to transactions within its scope, requires agreement to transact electronically, prevents denial of legal effect solely because a record or signature is electronic, and makes attribution depend on whether the act was the person's.

Before electronic rollout, confirm:

☐ The acknowledgment transaction is within § 668.50's scope.

☐ The participant agreed to conduct the transaction electronically.

☐ The system identifies the policy version and provides a retainable copy.

☐ Authentication and audit records support attribution.

☐ A nonelectronic route is available if required by the selected process.

☐ Any separate notice, consent, accessibility, collective-bargaining, or recordkeeping requirement is satisfied.

17. Employee Acknowledgment

Employee name: [________________________________]

Employee ID: [________________________________]

Job title / department: [________________________________]

Policy version: [________________________________]

Date received: [__/__/____]

☐ I received access to this Code and had an opportunity to ask questions.

☐ I understand the reporting channels and non-retaliation policy.

☐ I understand that I must follow the specific procedure identified for safety, privacy, testing, records, conflicts, and investigations.

☐ I understand that I must promptly report suspected misconduct or control failures.

☐ I disclose the following actual or potential conflict or compliance concern: [________________________________]

Acknowledgment method: ☐ Handwritten signature ☐ Approved electronic acknowledgment ☐ Other: [____________]

Signature or authenticated action: [________________________________]

Date: [__/__/____]

This acknowledgment records receipt and understanding. It does not waive a legal right, establish that every policy provision applies in every circumstance, or predetermine an investigation or corrective-action decision.

18. Adoption Checklist

Before publishing this Code:

☐ Insert all contacts, owners, and approval limits.

☐ Confirm the employer type, workforce, locations, and industry.

☐ Reconcile the Code with handbooks, agreements, benefit plans, and collective-bargaining obligations.

☐ Verify all federal, local, licensing, and industry-specific overlays separately.

☐ Approve the investigation, privacy, security, records, safety, conflict, gifts, and testing procedures cross-referenced here.

☐ Test every reporting channel and after-hours path.

☐ Confirm language access, disability access, and delivery method.

☐ Archive the approved version and change log.

Sources and References

• Fla. Stat. § 760.10 — Unlawful employment practices
• Fla. Stat. § 448.102 — Private-sector whistleblower prohibitions
• Fla. Stat. § 501.171 — Security of confidential personal information
• 2026 SB 7026 enrolled text — current-session § 501.171 overlay
• Fla. Stat. § 838.015 — Bribery
• Fla. Stat. § 440.102 — Drug-free workplace program requirements
• Fla. Stat. § 668.50 — Uniform Electronic Transaction Act