American Express

Driving Compliance From 60% to 95% in Under 3 Months

American Express required a global refresh of its existing Code of Conduct. Employees weren’t completing the training, and those that did often took up to 12 months to finish. The year before our involvement, completion rates hovered at 60% over 12 months.

After our refresh and campaign activation, Code of Conduct training and compliance rose to 95% completion in under 3 months.

Upon completion of our global interviews with employees from the CEO to employees working in distribution centers we created user personas as a litmus test for our messaging and communications campaigns.

Incognito Design, in partnership with k-nekt communications, launched the initiative with over two dozen employee interviews worldwide. We identified opportunities to:

  • Modernize the Code of Conduct
  • Improve the employee experience with the refreshed Code
  • Substantially increase compliance through innovative employee marketing and a more user-friendly design

My Company. My Code. My Life.

With heightened scrutiny of compliance and ethics programs by the federal government and the increasingly complex challenges faced by financial institutions, American Express needed a new approach.

Then-CEO Ken Chenault emphasized the company’s responsibility to be held to a higher standard and to remain accountable. For American Express to preserve its reputation, employees at every level—executives, middle managers, and call center staff—needed to be reminded of the complex risks of the marketplace.

The MyCode campaign was born. It quickly became a lightning rod for corporate ethics and compliance programs worldwide. Leveraging the iconic Amex Centurion, we crafted the call to action:

“My Company. My Code.”

This message resonated with 760,000 employees globally, urging them to take ownership, set a new standard for compliance, and reinforce brand values.

A Phased Approach

Phase 1: Insight & Discovery

We hosted a workshop with the Executive Leadership team to uncover obstacles with the previous Code of Conduct. Key steps included:

  • Workshops to understand leadership’s pressure points
  • 24+ global employee interviews to explore experiences, expectations, and channel preferences
  • Persona development to segment employee types and needs

“The smartest group I’ve ever met. You broke into the C-suite faster than anyone we’ve worked with.”
— Leonard Shen, Chief Compliance Officer

From this research, we identified five opportunities:

  1. Create and sustain user engagement
  2. Influence behaviors to better manage risk
  3. Deliver content through efficient, accessible channels
  4. Customize and target messaging
  5. Innovate employee training methods

Phase 2: Turning Insights Into Action

We translated insights into strategies that aligned with leadership’s goals:

  • Recognize the unique challenges employees faced and address them directly
  • Embed Blue Box Values seamlessly into the new Code of Conduct
  • Equip leaders and middle managers to evangelize the program
  • Provide quick-use tools to help leaders model behaviors and communicate effectively
  • Train program evangelists to maintain momentum and measure success

To ensure sustainability, we created a 2-year editorial calendar and communications plan. This living framework offered timely content, pre-written articles, presentation outlines, and adaptable templates to keep messaging relevant.

Phase 3: My Company. My Code.

We built a unique brand “love mark” for the campaign—eight vertical bars representing the Blue Box Values, paired with brand-inspired typography. This became a visual reminder of the connection between employees and the brand. The MyCode love mark was translated for over 15 different countries.

The MyCode love mark. Used on all Code communications and translated into 13 languages for global distribution.

To sustain adoption:

  • We developed the MyCode Toolkit, an onboarding booklet with Code updates and “timely topics.”
  • We launched an on-demand Code of Conduct microsite, giving evangelists 24/7 access to campaign resources: posters, flash cards, tent cards, PowerPoint slides, and more.

MyCompany. My CodeKit. A primer for all employees reducing the Code of Conduct language into thematic and easy to instructions to help employees internalize the new Code.

Campaign Deliverables

  • Code of Conduct refresh
  • Code of Conduct website
  • Flash cards
  • Activation & follow-up emails
  • Oversized fulfillment center posters
  • MyCode Toolkit (onboarding booklet)
  • Cafeteria tent cards

6 foot tall MyCode posters used in U.S. distribution centers.

A Message for the People

Employees were placed at the center of the program. They needed to know not only what the Code said, but how, when, and where to apply it. Our messaging captured this urgency:

  • “I am the guardian.” – personal accountability
  • “Now More Than Ever.” – timeliness and urgency

These statements appeared across internal collateral, including call centers, to ensure every employee felt directly connected to the mission.

End result: 

Unprecedented compliance and training adoption—95% completion in under three months—setting a new global benchmark for corporate compliance programs.

Email campaign for senior leaders, employees, save the date, Code champions, and managers.