Mosaic's Code of Conduct: Review, Redesign, Communication and Certification - A Transformation

“SAI Global gave us the complete package fully supported: excellent content and project management with valuable strategic insight.”

A Challenging Brief 


The Mosaic Company's origins as the product of a 2004 merger of two well-established international crop nutrition businesses presented the organization with two significant challenges when developing and promoting its business conduct standards. Not only was it now vital for over 7,000 people to understand and apply legal and ethical standards consistently across 10 countries on four continents, they needed to make sense of their responsibilities from reference points rooted in different corporate and regional cultures.  Mosaic's Code of Business Conduct and Ethics was to be the primary focus and tool in this effort to educate and integrate. The effort could only successfully engage and inspire employees if the Code embodied the values and principles representing the best of the two former organizations and their cultures.

In the face of such challenges, Mosaic's efforts took some time to reach fruition. In its 2005 version, the Code was functional and technically accurate but the text-only, legal-flavored document fell short of the Company's aspirations to engage and assist employees with their day-to-day concerns. Additionally, training employees was complicated, due in part to the company's large population of geographically dispersed, hourly workers. 

Shifting from Integration to Shared Commitment

By the summer of 2008, the Company had a new corporate strategy in place, focusing on four core values: integrity, excellence, sustainability and connectivity. A February 2008 re-launch of the Code had addressed emerging business conduct issues and maintained the document's legal accuracy, but it did not incorporate the new values. At this point, Mosaic decided to partner with SAI Global, with a goal of transforming not only the Code but also employees' perception and use of it. SAI Global's team was tasked with creating a document with a strong values orientation, with the aim of unifying employees globally around the Company's mission and shared values and beliefs, promoting a culture of robust commitment to ethics and compliance with the law.  

Developing an Effective Code


Discussions with Mosaic's senior leadership set the context, project objectives and an aggressive timeline. SAI Global's thorough review of the current Code resulted in a number of recommendations for additional risk areas and other topics to be covered. Development work began in January 2009. Although typically a full text draft is presented to a client before graphic design is considered, it was important to Mosaic to be able to present a partial mock-up of the new Code to its Board at an early stage. SAI Global's collaborative spirit and flexibility of approach facilitated swift approval from the Board to move forward. While elements of the former Code were retained, the structure and text that emerged from a number of drafts was nothing short of transformative.

A Transformation with a Business Bent

The new Code is unrecognizable from the one it replaces: vibrant, vital and engaging, with a priority focus on language, tone and structure to promote acceptance and ease of use. The new Code features numerous reader aids and the judicious use of images featuring the diversity of the Company's locations and people.  It was designed this way to position the Code as a relevant, important, and useful business document, not a remote legal mandate.


SAI Global delivered the new Code in record time in a very cost-effective way. 

SAI Global’s team understands that developing a Code is so much more than a drafting exercise. They have unquestionable technical drafting ability but, critically, know how to structure and articulate ethics and compliance messages so they align with the business and inspire individual and collective success

Mark Isaacson

Vice President - Law

Communicating the New Code


A new communication campaign helped translate the Company's commitment into individual action. The new Code was released on Mosaic's public website and communicated internally with a link to the full Code.  Paper copies were also mailed to the homes of each of Mosaic's 6,500+ North American employees.  By making the Code visible to all employees and positioning it as a business resource rather than a legal document, Mosaic quickly began to build a philosophy which would become embedded into the culture of the organization. An annual Code certification process acknowledged employees' receipt of the document and a personal commitment to honor its standards. 

To further reinforce the values and guidelines incorporated in the Code, SAI Global worked with Mosaic to design an awareness-raising and training program to educate employees. Starting with the Best Practices Code of Conduct course, Mosaic chose segments from SAI Global's course library that highlighted specific key risk areas identified in their Code. This customized course, including a video introduction from the Company's CEO, presented appropriate scenarios that were relevant and engaging for the global workforce.

Ongoing training helps ensure that employees understand and correctly apply the Code, living by its values and principles.

Living the Code

Annual survey results note positive feedback from Mosaic employees. The new Code allows employees to have a better understanding of and connection with the Company's values. Mosaic has also achieved high completion rates for the Best Practices Code of Conduct course and plans to launch SAI Global's Ethical Moments®: innovative 3-5 minute video vignettes that reinforce key messages through memorable, real-life examples.


About Mosaic

Mosaic was formed in 2004 through the combination of IMC Global Inc. and the crop nutrition business of Cargill, Incorporated. Headquartered in Plymouth, Minnesota, we employ approximately 7,400 people in ten countries. Shares trade on the New York Stock Exchange under the ticker symbol MOS.



About SAI Global Compliance

For twenty-five years, SAI Global Compliance clients have built stronger corporate cultures and more effective all-around programs with our compliance, risk management and governance solutions. With offices in more than 25 countries, SAI Global provides risk and culture assessments; Code of Conduct reviews, development and training; award-winning, innovative online training; training needs assessments; benchmarking and surveys; hotline, ethics reporting and case management solutions; risk- and region-specific updates, databases, regulatory alerts and newsfeeds; and technology solutions that integrate and connect all aspects of a legal or regulatory compliance program.