Based on guidelines produced by participants in the conference, companies were encouraged to formulate policies, suited to their business nature, for proper conduct.

Of the 20 companies that had supposedly started drafting their own codes in line with conference guidelines, the ICAC struggled to track down six companies willing to speak about their progress.

''All companies approached by the ICAC were very positive to the idea of a code,'' said Helen Lee, the ICAC's community relations officer. ''Perhaps they're too busy.'' While many applauded the ICAC's campaign, of the six companies contacted by the South China Morning Post, only one had finished drafting a code based on conference guidelines. Two others had had their own codes in place for a number of years without consultation from the ICAC.

Gordon Wu Ying-sheung, managing director of Hopewell Holdings and a convener of a workshop at the conference, declined to comment on his company's progress.

Sino Land Co chairman Robert Ng Chee Siong, another convenor at the conference, spoke highly of the ICAC and the value of business ethics, but his company has been slow to act.

It has yet to decide whether to create a code. Director of human resources and administration Doreen Fung said: ''This is a hard question. Let's just say we are considering it.'' Mr Ng said: ''The ICAC has been tremendously helpful in promoting ethics.'' On the benefits of codifying standards, he said: ''People want to deal with companies with good integrity and honour. It all adds up to pluses.'' Hongkong Electric Holdings is moving slowly but surely towards putting together a code.

Minnie Li, manager of the utility company's personnel and administration, said listed companies had a responsibility to the public.

She said older Hong Kong companies all had staff guidelines, a section of which covered the ordinance on corruption.

But she said companies should establish specific codes so that employees would be sure of what was expected of them.

She said because Hongkong Electric engaged in complex tendering procedures the guidelines must be comprehensive enough to deal even with traditional offerings of lai see (red packets of lucky money).

Ms Li said it was difficult to determine at what price a gift became a bribe.

''Obviously you have a code of conduct when dealing with colleagues. But a code of ethics is different because it also deals with outsiders.'' Hongkong Electric began formulating its code with extensive consultation from two committees, a senior level and a junior level, consisting of staff from all sectors of operations.

A working group will continue to answer dissent, monitor progress and update the code after implementation.

The company expects a final draft by September, with copies given to all 2,900 staff members in English and Chinese within the year.

Consultation between staff and management has been extensive. But there is no process to monitor code violations, just a blanket internal disciplinary process.

Ms Li said it was difficult to gauge how a breach of the code would be dealt with, as it depended on the severity of the violation.

Richard Bennett, Hongkong and Shanghai Bank's legal adviser, said: ''There is no use having a code if it has no teeth.'' He said the bank's code of conduct was written into the employment contracts.

The penalty for breaching the code is dismissal.

Monitoring is done with a combination of spot checks and internal procedures.

Codes of conduct were made mandatory for all Hong Kong banks in 1986 by then commissioner of banking Robert Fell.

The seven-page code was drafted by executive staff without consultation with staff members. The code is reviewed, but not on a regular basis. Changes recommended by the legal adviser and human resources are approved by the chairman.

Mr Bennett credited the ICAC for raising an important issue and getting the ball rolling.

''The best way to implement a code is if it is adopted by a profession or sector,'' he said.

Gordon Tsang, manager of business practices and security at IBM, said a written code was a necessity for big companies.

IBM has had a formal code for more than 30 years and its Business Conduct Guidelines is the 15th version. IBM issues a uniform guidebook for employees worldwide.

The 28-page guidebook covers everything from the ownership of programs written at home or on company terminals to employee involvement in public service.

The document is revised and reprinted about every two years.

Mr Tsang said even if no changes were in the guidebook, different coloured covers put renewed emphasis on the topic.

All regular employees, about 850 in Hong Kong, are required to certify that they have read, understood and abide by the guidebook.

While there are internal disciplinary measures, Mr Tsang said education was the prime focus in IBM's approach.

''Every employee gets orientation with emphasis on business ethics from the start,'' he said.

Depending on the type of violation, most would probably result in counselling from managers. IBM relies heavily on middle managers to voice staff feedback and to monitor behaviour. Every immediate manager oversees fewer than 10 employees.

Mr Tsang said: ''It takes time to create the [ethical] culture.'' It took Hang Lung Development's company secretary and financial controller Robin Ching one month to draft a code, based solely on ICAC guidelines with no input from its 2,000 employees.

The code was implemented a month ago. All monitoring, updating and consultation is handled by Mr Ching and his secretary. Staff with inquiries or grievances are expected to go to the department head or Mr Ching.

A month is not much time to put together a code of conduct. But, at least it is better than no code at all.

A SUMMARY of the formulation and implementation guidelines from the ICAC conference.

Initiative must come from top management.

It is essential functional managers have input on drafting and implementation; the more involved the greater the commitment.

Ethical behaviour must be enforced and unethical behaviour dealt with decisively and quickly.

A formal channel to receive complaints of alleged breaches of conduct should be established and made known to employees, clients, etc. A code cannot work without this.

Complaints should be followed up expeditiously, preferably by a senior ranking officer with title of chief internal auditor.

Usually line managers oversee staff compliance with codes; a high-ranking officer should be assigned to co-ordinate and monitor implementation. The title would be compliance officer.

It is preferable to have a complaints officer report to the compliance officer, rather than the same person holding both positions.