Code of Conduct - Signature FAQs

Type of Signature

Question: Is an electronic signature acceptable for the initial signing upon hire and annual signing? 

  • Answer: As of March 2026, yes.

Question: Is proof of completion of the Justice Center Code of Conduct in the Statewide Learning Management System (SLMS) sufficient to confirm that the training was completed? 

  • Answer: Yes. Click here for the digital signature guidance to ensure compliance.

Timing of Code of Conduct Signature

Question: By law, the Code of Conduct must be signed annually--does that mean no later than exactly one year from the date of the original signature?  For example, if an employee signed upon hire on August 18, 2025, is it acceptable for that employee to re-sign the Code of Conduct annually on a date that falls after August 18?

  • Answer: The Justice Center accepts signatures within 6 months of the original due date (ex: if the original signature was August 18, 2025, the employee has until February 18, 2027 to re-sign. Any date after that would be considered out of compliance).

Question: Should new employees sign the annual attestation at the same time as other staff if they have not yet been with the agency/school for a full year?  For example, if a new employee joins and signs the Code of Conduct in July and the agency/school has all staff sign the attestation in September annually, should new staff who just signed the Code of Conduct sign the attestation again in September?  

  • Answer: This is up to the provider, but it is recommended that all staff are on the same schedule for annual attestation. There is no penalty for signing the Code of Conduct too frequently.

Training Requirements

Question: Does the Code of Conduct training have to be delivered as its own program? Is it acceptable to incorporate the presentation into existing agency training programs? 

  • Answer: The Code of Conduct may be part of an agency’s other training requirements if there is documentation specifically noting that the Justice Center’s Code of Conduct training was completed with a signature by the staff.

Question: Can an agency create its own attestation of the Code of Conduct?

Question: Can an agency modify parts of the Justice Center’s Code of Conduct to incorporate its own expectations for staff conduct?

  • Answer: No. The complete Justice Center Code of Conduct is the only acceptable Code of Conduct to satisfy the legal requirement. 

Language Access

Question: How do I obtain the Code of Conduct in a language other than English?

Other Questions

Question: Is the Code of Conduct updated annually? 

  • Answer: No. If there is ever a change made to the Code of Conduct, the relevant State Oversight Agencies will be notified so they may communicate with impacted providers.

Question: Do investigators ask for Code of Conduct signatures as part of an investigation? For example, if during an interview, a subject says they were not properly trained on the Code of Conduct – would the investigator pull those records to confirm or deny?

  • Answer: Yes, Justice Center investigators always request proof of relevant training, including the Code of Conduct.

Question: Is the Justice Center Code of Conduct Train the Trainer mandated for everyone who signs the Code of Conduct?

  • Answer: No. 

Question: Are third-party vendors (contracted staff or volunteers) required to sign the Code of Conduct? 

  • Answer: It is in the best interest of the agency to ensure that people permitted to have regular and substantial contact with individuals receiving services sign the Code of Conduct and receive relevant training. Training on the Code of Conduct protects individuals receiving services, while also protecting the contracted staff or volunteer from unknowingly putting people at risk.  It also protects the agency.

All staff, contractors, volunteers, or third-party vendors who provide services and are permitted to have regular contact with people receiving services can find relevant training programs on the Justice Center website: 

 

 

 

 

If you have a question about the Code of Conduct that is not included in this FAQ, please contact the Justice Center Office of General Counsel at [email protected].