As all securities lawyers know, the Sarbanes-Oxley Act introduced new provisions relating to codes of ethics. Section 406 of the Act requires that companies disclose whether they have a code of ethics for their senior financial officers, and if not, the reason why not. This has led many companies to adopt codes of ethics.
I don’t think that the market has realized how simple this requirement actually is. As with most other areas of life, the best course here is simply to follow the guidance of Chuck Norris. To make this easier, Chuck has provided a clear list of “Chuck’s Code of Ethics.” (link via sharp-eyed reader Steve Evans). A company simply needs to adopt the list wholesale, and it can’t go wrong.
What does Chuck’s code provide? A few highlights:
“I will develop myself to the maximum of my potential in all ways.
I will forget the mistakes of the past and press on to greater achievements.
I will always be in a positive frame of mind and convey this feeling to every person that I meet. . .”
Does Chuck’s code meet the requirements of Item 406 of Reg S-K? You might as well ask, “Does Chuck Norris have a beard?”