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UH Law Center debuts first database of Fortune 500 company codes of conduct

Oct. 9, 2014 – The University of Houston Law Center today released a searchable database that contains the compliance codes for Fortune 500 companies.  The project was led by Houston attorney Ryan McConnell, an adjunct professor at the University of Houston Law Center. McConnell worked with a team of recent graduates and current students to develop the database, which covers 42 different topics.

“The free database allows any company to conduct benchmarking on virtually every compliance area covered in a code of conduct and to spot compliance trends within their industry,” McConnell explained.

“In addition to proactively building a program, when compliance failures occur, whether a foreign bribery violation or environmental issue, stakeholders – whether they are shareholders in a lawsuit or criminal investigators – frequently scrutinize the company’s compliance program.  This database provides a powerful tool for anyone to evaluate the strength of a company’s compliance program, including subject matters addressed in the code and the organization’s core values.”

The Wall Street Journal has already dubbed the online tool as “catnip for compliance officers.” More than 2,000 hours have been devoted to maintaining and updating the database since
McConnell began the project in 2010 with the assistance of Akin Gump associate Katherine Southard Frazier and UH Law Center web developers Ruth McCleskey and Baroness Adams.

McConnell is a former federal prosecutor who focuses his practice on corporate compliance issues, internal investigations and white collar criminal defense with the Houston firm of McConnell Sovany LLP.  He has taught international corporate compliance and criminal procedure at the Law Center for several years.  The project was an outgrowth of the compliance work McConnell does for his client, where he identified a lack of publicly available resources for companies to benchmark their programs.   

Most recently, McConnell has noticed an increased focus on social media and security issues. Social media policies experienced a 150 percent growth in codes of conduct since 2011, increasing from 88 companies to 220 companies in the latest dataset.  Privacy policies addressing the protection of personal identifying information is included in 350 company codes.  Out of those companies, three mention safe harbor certification and only one mentions approval of its binding corporate rules.  This is consistent, he said, with the notion that data privacy and data security are dynamic areas as companies evaluate the information they hold and process to determine which of the two programs best suits their company.  The number of companies with “whistleblower” policies more than doubled from 34 in 2011 to 71 in 2013.  

The database was updated this year by the University of Houston's Business and Tax Journal, working with UH alumna Michelle Jee and several other UH students. Other current and former students who assisted with the project include Kevin Baker, Aaron Blair, Paula Bonavides, Shaun Cassin, Briana Deanne, Angeles Garcia, Elli McKean, Erin Mitchell, Charlotte Simon, Ashley Whittington, and Katherine Witty.

To access UH Law Center’s compliance database, go to
University of Houston Law Center Media Contacts: Carrie Anna Criado, UH Law Center Executive Director of Communications and Marketing, 713-743-2184,; John T. Kling, UH Law Center Communications Manager, 713- 743-8298,; or Stephen B. Jablonski, Multimedia Specialist, 713-743- 1634,

About the University of Houston

The University of Houston is a Carnegie-designated Tier One public research university recognized by The Princeton Review as one of the nation's best colleges for undergraduate education. UH serves the globally competitive Houston and Gulf Coast Region by providing world-class faculty, experiential learning and strategic industry partnerships. Located in the nation's fourth-largest city, UH serves more than 39,500 students in the most ethnically and culturally diverse region in the country.

About the University of Houston Law Center

The University of Houston Law Center is the leading law school in the nation's fourth-largest city. Founded in 1947, it is a top-tier institution awarding Doctor of Jurisprudence (J.D.) and Master of Laws (LL.M.) degrees. The Law Center is fully accredited by the American Bar Association and is a member of the Association of American Law Schools.

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