Most large organizations post their code of conduct on their website.
If one were to download a sample (or even a complete census of all
1000)...and subject these codes to some sort of readability
test...what would be the average score? Who would shine? Who would be
shamed?

I'm not sure what the best tool would be for analyzing the text. MS
Word has a built-in tool. There is a pretty cool utility here:
http://www.fightthebull.com/ that finds "BS" in documents.

At any rate, this would be a fun project.

---

Request for Question Clarification by guillermo-ga on 16 Feb 2006 19:04 PST

Hello Hogayoga,

This sure seems an interesting question, but I'm not sure to
understand it completely. Would you please precise what the outcome
you expect would be? Thank you in advance.

Guillermo

---

Clarification of Question by hogayoga-ga on 16 Feb 2006 19:19 PST

For example, if you go to
http://www22.verizon.com/about/careers/pdfs/CodeOfConduct.pdf you can
get a copy of Verizon's code of conduct. When I convert the document
into MS Word, open the document, and check spelling and grammar with
"readability statistics" I find that the document has:

- a Flesch Reading Ease score of 23.0 (which is bad)
- a Flesch-Kincaid Grade Level of 14.9 (meaning one needs a 15th grade
reading level...most of America has an 8th grade reading level)

As such, itmay be possible that Veriaon, a company that employs a
fairly representative sample of Ameerica, is not effectively
communicating with its employee re: its expectations of conduct.

---

Request for Question Clarification by guillermo-ga on 16 Feb 2006 22:21 PST

Hello again,

I'm willing to work on this question. Now, censing 1000 cases, or even
100 would not be feasible within this framework, because of the time
it would demand -- each company's website is organized differently, so
a variable browsing time will be required to find the searched text.
Also, text analysis will require copying and pasting it, so those
blocked to copy will have to be excluded.

That said, I would suggest you told me what organizations you'd like
to see included in a sample. Thank you.

Guillermo

---

Clarification of Question by hogayoga-ga on 17 Feb 2006 13:54 PST

I'd like the survey to be random. As such, I will run a randomization
algorithm on a spreadsheet of the Fortune 1000 and select 50
organizations. Would that work? I can upload the spreadsheet to a
publicly available and free webspace. Will that work?

---

Request for Question Clarification by guillermo-ga on 17 Feb 2006 18:41 PST

It sounds fine. Please post the URL to the spreadsheet once you've got it. Thanks.

Guillermo

---

Clarification of Question by hogayoga-ga on 20 Feb 2006 15:29 PST

OK. I randomized the list on just the Fortune 500 and got this list of
companies. This list includes the company name and their "ticker" so
that you can more easily find their web address, etc. I will upload a
spreadsheet to a public space shortly.

Edison International	EIX
International Paper	IP
Valero Energy	VLO
Office Depot	ODP
Winn-Dixie Stores	WIN
OM Group	OMG
Amazon.Com	AMZN
Universal Health Svcs.	UHS
Hilton Hotels	HLT
Lear	LEA
Target	TGT
Anheuser-Busch	BUD
Prudential Financial	PRU
Avaya	AV
Dillard's	DDS
Armstrong Holdings	ACKH Q
Pfizer	PFE
Goldman Sachs Group	GS
Edison International	EIX
Allied Waste Industries	AW
KB Home	KBH
Farmland Industries
Levi Strauss
Rite Aid	RAD
Genuine Parts	GPC
American Express	AXP
Kerr-McGee	KMG
Amazon.Com	AMZN
Sealed Air	SEE
SouthTrust Corp.	SOTR
Ace Hardware
Pathmark Stores	PTMK
Sierra Pacific Resources	SRP
May Dept. Stores	MAY
Altria Group	MO
Pepsi Bottling	PBG
Unisys	UIS
Xcel Energy	XEL
Federal-Mogul	FDML Q
Comcast	CMCS K
Kroger	KR
DuPont	DD
Exxon Mobil	XOM
PepsiAmericas	PAS
Tyson Foods	TSN
FPL Group	FPL
McGraw-Hill	MHP
Verizon Communications	VZ
Lear	LEA

---

Request for Question Clarification by guillermo-ga on 20 Feb 2006 16:28 PST

Great! I'm into it. Thanks.

---

Clarification of Question by hogayoga-ga on 20 Feb 2006 16:36 PST

OK. The file is uploaded to:

http://h1.ripway.com/hogayoga/

It is called CodesofConduct.xls. This is the random list (using a
software-based pseudorandom number generator) of Fortune 500 companies
that I would like to analyze.

In column "N" I have included the website address for most of the
companies. I would propose that we add 2 more columns to the
spreadsheet that include:
- Flesch Reading Ease score
- Flesch-Kincaid Grade Level score

These scores will come from a MS Word analysis of their code of
conduct. If possible, it would be great if you could download all of
these codes of conduct and include them in your result. That way, we
can have a record of what was actually analyzed.

thanks!

---

Request for Question Clarification by guillermo-ga on 20 Feb 2006 18:23 PST

OK. There'll be no problem but for the downloading of the codes of
ethics themselves, if for that you mean reproducing their texts. I
would willingly do so, but I believe we would be infringing copyright
laws. Instead, I could add another column for the URL's of the
specific pages where the codes of ethics are. Is that OK?

G.

---

Clarification of Question by hogayoga-ga on 21 Feb 2006 10:01 PST

URL would be ideal. Thanks!

---

Request for Question Clarification by guillermo-ga on 22 Feb 2006 22:35 PST

Just an update: I've accomplished about the third part of the task. I
came across an unexpected difficulty that slowed it down. When codes
of ethics are on HTML documents, doing the checking is relatively fast
-- copy, paste, almost no editing, and it's done. Now, many are in PDF
(Adobe) documents. In these cases, the process "copy-paste-check" does
not suffice, and a lot of editing is needed before checking because,
when pasting into a Word document the text copied from Adobe, Word
assumes each row as a paragraph, splitting many sentences, which are
then interpreted as incomplete (senseless) by the grammar checker --
thus impacting on the Flesch Reading Ease and Flesch-Kincaid Grade
Level scores. I did a try with and without previous editing and the
difference proved significant. Hence, a "copy-paste-edit-check"
process will be necessary, being the "edit" step the most time
consuming. Thanks for your patience.

Guillermo

---

Clarification of Question by hogayoga-ga on 24 Feb 2006 13:45 PST

Understood. Thanks for your diligence.

Hello Hogayoga,

We're finally there :)

Of the 50 cases of the sample, I could review 44. All the 50 are
listed below. For each, the first line is the company name, the second
the company website's URL, the third one the code of ethics' URL, the
fourth is the Flesch Reading Ease (FRE) score, and the fifth
corresponds to the Flesch-Kincaid Grade Level (FKGL) -- except for
those that I couldn't find, which instead have the respective
explanation. Also, you can retrieve the original Excel file with the
result of this search added at

http://us.f2.yahoofs.com/bc/3ccd1ef5/bc/Code_of_Ethics/973a.xls?bfJp5_DBpHoxkJ2r

Interestingly, for all cases the FKGL is 12. As I told you in a
previous post, to avoid testing distortions due to formatting
alteration when changing from Adobe to Word, in most cases I had to do
 some editing -- such as removing paragraph marks from the middle of
the sentences or others of the kind; nothing that would modify the
comprehensibility of the original test -- but time consuming for
documents ranging from 20 to 80 pages. Well, only when I performed the
test before editing the FKGL scored over 12.

As to FRE, the average was 22.68, very close to the median -- 22.60.
The highest score was 36, achieved by Edison International, while the
lowest is hold by Universal Health Services, with 7.8 -- in an abrupt
fall, the next value is 14.70 (Hilton Hotels). There are three values
repeating two occurrences each: 22.50 (Goldman Sachs Group /
McGraw-Hill), 23.60 (Kroger / Office Depot), and 27.80 (Lockheed /
SWA).

According to these results, 41 out of 44 (93.18%) have scored below 30
-- the three above 30 are Starbucks Corporation, YUM! and Edison
International; American Express was very close with 29.90 and next
Genuine Pars with 29.20. Below 30 is considered "best understood by
college graduates" in the corresponding article at Wikipedia
(http://en.wikipedia.org/wiki/Flesch-Kincaid_Readability_Test ). So, I
would interpret these results as expressing that a 12th grader could
read these texts but not necessarily understand them -- unless maybe
with an important effort.

The stats are calculated in the spreadsheet at
http://us.f2.yahoofs.com/bc/3ccd1ef5/bc/Code_of_Ethics/Stats.xls?bfn25_DBelv3OBs7

By the way, this text is FRE 45.3 and FKGL 9.5. But, if not
considering the list below, it changes to FRE 35.1 and FKLG 12.

I hope this answer has met your expectations. However, please do not
hesitate to ask for clarification if needed.

Regards,

Guillermo

The results:

Ace Hardware
http://www.acehardware.com
CODE OF ETHICS NOT FOUND

Allied Waste Industries, Inc.
http://www.alliedwaste.com
http://media.corporate-ir.net/media_files/IROL/74/74587/corpgov/CodeofEthics0304.pdf
24,1
12

Altria Group, Inc.
http://www.altria.com
http://www.altria.com/download/pdf/about_altria_BOD_codeethics.pdf
20,3
12

Amazon.com, Inc.
http://www.amazon.com
http://phx.corporate-ir.net/phoenix.zhtml?c=97664&p=irol-govConductPrint
23,1
12

American Express Company
http://www.americanexpress.com
http://ir.americanexpress.com/phoenix.zhtml?c=64467&p=irol-govConduct
29,9
12

Anheuser-Busch Companies, Inc.
http://www.anheuser-busch.com
http://www.corporate-ir.net/ireye/ir_site.zhtml?ticker=BUD&script=2250
18,4
12

Armstrong Holdings
http://www.armstrong.com/
http://www.armstrong.com/common/uscorp/content/files/5608.pdf
24
12

Avaya Inc.
http://www.avaya.com
http://investors.avaya.com/governance/conduct.shtml
17
12

Comcast Corporation
http://www.comcast.com
http://www.cmcsk.com/phoenix.zhtml?c=118591&p=irol-govConduct
15,4
12

Dillard's, Inc.
http://www.dillards.com
http://www.shareholder.com/dillards/conduct.cfm
15,1
12

E. I. du Pont de Nemours and Company
http://www.dupont.com
http://www2.dupont.com/Social_Commitment/en_US/assets/downloads/conductguide/Business_Ethics_Policy_and_Procedures.pdf
21,2
12

Edison International
http://www.edison.com
http://media.corporate-ir.net/media_files/irol/85/85474/reports/200509_ethics_code.pdf
36
12

Exxon Mobil Corporation
http://www.exxon.mobil.com
http://www.exxonmobil.com/corporate/files/corporate/Code_ethics.pdf
FILE PROTECTED -- UNABLE TO COPY

Farmland Industries
http://www.farmland.com/
I FOUND THE CORPORATE URL BUT IT GRANTS NO ACCESS, SHOWING MESSAGE:
"You are not authorized to view this page"

Federal-Mogul Corporation
http://www.Federal-Mogul.com
http://www.federal-mogul.com/vgn/images/portal/cit_776/15974723Integrity%20Program%20.pdf
22,7
12

FPL Group, Inc.
http://www.fplgroup.com
http://www.fplgroup.com/governance/contents/code_of_conduct.shtml
19,2
12

Genuine Parts Company
http://www.genpt.com
http://www.genpt.com/corporate/GPC_New_Code_of_Conduct_(Summer_2003_Version).pdf
29,2
12

Goldman Sachs Group
http://www.goldmansachs.com
http://www.goldmansachs.com/our_firm/investor_relations/corporate_governance/articles/corporate_governance_030224195742.html
22,5
12

Hilton Hotels
http://www.hilton.com/en/hi/index.jhtml
http://media.corporate-ir.net/media_files/irol/88/88577/corpgov/codeofethics_013004.pdf
14,7
12

International Paper Company
http://www.ipaper.com
http://www.ipaper.com/Our%20Company/Ethics%20and%20Business%20Practice/Code%20of%20Business%20Ethics.html
26,6
12

KB Home
http://www.kbhome.com
http://media.corporate-ir.net/media_files/IROL/11/111266/Ethics.pdf
15,3
12

Kerr-McGee Corporation
http://www.kerr-mcgee.com
http://www.kerr-mcgee.com/SiteObjects/files/code0703.pdf
17,1
12

Kroger
http://www.kroger.com
http://www.thekrogerco.com/documents/EthicsPolicy.pdf
23,6
12

Lear Corporation
http://www.lear.com
http://ir.lear.com/downloads/ir_cg_conduct.pdf
20,2
12

Levi Strauss & Co.
http://www.levistrauss.com
CODE OF ETHICS NOT FOUND

Lockheed Martin Corporation
http://www.lockheedmartin.com
http://www.lockheedmartin.com/data/assets/7856.pdf
27,8
12

May Department Stores
http://www2.mayco.com/common/index.jsp
I FOUND THE CORPORATE URL BUT NOT THE CODE OF ETHICS IN THE WEBSITE

McGraw-Hill
http://www.mcgraw-hill.com
http://investor.mcgraw-hill.com/phoenix.zhtml?c=96562&p=irol-govcobe
22,5
12

Office Depot, Inc.
http://www.officedepot.com
http://www.officedepot.com/companyinfo/companyfacts/ethics.pdf
23,6
12

Omnicom Group Inc.
http://www.omnicomgroup.com
http://www.omnicomgroup.com/governance/codeofconduct
19,1
12

Pathmark Stores, Inc.
http://www.pathmark.com
http://www.pathmark.com/cminc/pdf/investor-sec/CodeofConduct.pdf
26,1
12

PepsiCo, Inc.
http://www.pepsico.com
http://www.pepsico.com/PEP_Investors/CorporateGovernance/CodeofConduct/english/images/Code_of_Conduct.pdf
25,9
12

Pfizer Inc
http://www.pfizer.com
http://www.pfizer.com/pfizer/download/investors/corporate/business_conduct_policies_summary_2003.pdf
26,2
12

Prudential Financial, Inc.
http://www.prudential.com
http://www.investor.prudential.com/downloads/MakingTheRightChoices2.pdf
16,7
12

RadioShack Corporation
http://www.radioshack.com
http://media.corporate-ir.net/media_files/NYS/RSH/gov/RSH_CodeOfEthics.pdf
20,8
12

Rite Aid Corporation
http://www.riteaid.com
http://www.riteaid.com/company_info/images/code_of_ethics.pdf
19,3
12

Sealed Air Corporation
http://www.sealedaircorp.com
http://www.sealedair.com/corp/conduct.html#conduct
24,9
12

Southwest Airlines Co.
http://www.southwest.com
http://www.southwest.com/investor_relations/fs_corporate_governance.html
27,8
12

Starbucks Corporation
http://www.starbucks.com
http://www.starbucks.com/aboutus/US_English_full_kit.pdf
32,5
12

Target Corporation
http://www.target.com
http://media.corporate-ir.net/media_files/irol/65/65828/corpgov/business_conduct_guide.pdf
21,7
12

Tyson Foods, Inc.
http://www.tysonfoodsinc.com
http://media.corporate-ir.net/media_files/irol/65/65476/govDocs/codeofconduct.pdf
28,7
12

Unisys Corporation
http://www.unisys.com
http://www.unisys.com/common/investors/other/Code_of_Ethics.pdf
25,6
12

Universal Health Services, Inc.
http://www.uhsinc.com
http://www.uhsinc.com/ir_governance1.php
7,8
12

Valero Energy Corporation
http://www.valero.com
http://www.valero.com/NR/rdonlyres/25F13BDB-3B40-4A82-A62C-CF3B4246E687/0/03CodeofBusinessConductandEthics08062004.pdf
19,7
12

Verizon Communications Inc.
http://www.verizon.com
http://www22.verizon.com/about/careers/pdfs/CodeOfConduct.pdf
20,4
12

Winn-Dixie Stores, Inc.
http://www.winn-dixie.com
http://www.winn-dixie.com/company/governance/Code_of_Conduct_040104.pdf
28,3
12

Wisconsin Energy Corporation
http://www.wisconsinenergy.com
THE CORPORATE URL WOULDN'T WORK

Wm. Wrigley Jr. Company
http://www.wrigley.com
http://media.corporate-ir.net/media_files/NYS/WWY/conduct2.pdf
27,7
12

Xcel Energy Inc.
http://www.xcelenergy.com
http://www.xcelenergy.com/XLWEB/CDA/0,3080,1-1-1_18554_24076-2217-0_0_0-0,00.html
16,6
12

YUM! Brands, Inc.
http://www.yum.com
http://www.yum.com/governance/media/gov_conduct092404.doc
32,6
12

---

Clarification of Answer by guillermo-ga on 24 Feb 2006 15:55 PST

Sorry for the glitch with the URL. This one should work:

http://us.f2.yahoofs.com/bc/3ccd1ef5/bc/Code_of_Ethics/973a.xls?bfnD6_DBMXwzkJ2r

If not, please let me know and we'll figure out an alternative. Thanks.

Guillermo

---

Clarification of Answer by guillermo-ga on 24 Feb 2006 17:46 PST

Evidently, these URLs I've been using are not stable any more. I'll
look for an alternative and let you know. Just in case, if you think
of posting your email in order to help, please DO NOT, because it's
against Google Answers rules. Sorry for the inconvenience.

Guillermo

---

Clarification of Answer by guillermo-ga on 24 Feb 2006 19:36 PST

Hi again,

Please try these ones now:

http://h1.ripway.com/mirarki/CodesOfConduct.xls

http://h1.ripway.com/mirarki/Stats.xls

---

Request for Answer Clarification by hogayoga-ga on 25 Feb 2006 08:19 PST

great job. can you clarify the stats spreadsheet?

---

Clarification of Answer by guillermo-ga on 25 Feb 2006 09:50 PST

Thank you. Sorry for the confusing stats spreadsheet. I edited it --
apparently uploading it with the same URL didn't work. Please give it
a look at http://h1.ripway.com/mirarki/Stats2.xls and let me know
whether now is clear enough or you expect something else. Thanks.

Guillermo

Good work -- done quickly

Thank you very much, Hogayoga, for the rating and tip :)

Best regards,

Guillermo