Ford's new ethics code: how would it look?

Could your conduct withstand public scrutiny? If your conduct was disclosed to management and reported in the media, would you be able to justify it as lawful and appropriate?

That's the gist of Ford Motor Co.'s new Standards of Corporate Conduct governing what's proper behavior in doing business with suppliers and other customers.

But unlike the more draconian measures put in writing by General Motors Corp. last May, Ford leaves room for personal judgment.

Take, for example, the case when a supplier may have box seats to a sporting event.

Under the new Ford policy no employee can ask a supplier for tickets. Ah, but if the supplier offers the tickets?

The ethics gospel according to Chairman Alex (Trotman):

"If there is a legitimate business purpose, it's all right to accept gifts and favors that are freely offered ... subject to these important limitations:

* The gift must be of a nominal value and involve no more than normal sales promotion or publicity.

* Social amenities must be appropriate and limited and must never give the appearance of impropriety.

* Any discounts on goods or services offered to you by a supplier must be made generally available and cannot be for your benefit only.

* You may never accept cash or gift certificates or food or alcohol.

* You may not borrow money, except from qualified financial institutions on generally available terms.

Compared with GM's policy, which effectively prohibits a Delphi Automotive Systems employee from buying lunch for a GM purchasing agent, Ford's guideline seem quite reasonable.

But what about investing in suppliers or any outside business that might do business with Ford?

The new code requires you to seek a special waiver if you hold any financial stake in a proprietorship or partnership that might sell to Ford, or more than 1% of the outstanding stock of a company. The waiver must be signed either by Chairman Trotman or John W. Martin, Ford's vice president and general counsel.

This clearly makes sense for the Grade 16 executive who has considerable influence over sourcing of parts that go into vehicles. But what about the loyal worker in the trenches who owns part of a spouse's floral shop or catering business that sometimes sells to a Ford office?

A literal interpretation of the rules says they both must get the waiver. Presumably in the latter case it would be granted. Maybe.