The Code of Conduct is often called the “cornerstone” of a compliance program, and getting your Code right can have a big impact. Just ask Kelleen Brennan, Associate General Counsel at Carvana — and the guest on our latest Zoom chat!

Kelleen has been a Rethink client since 2017, when she was charged with standing up Carvana’s compliance program from scratch. In part one of their Zoom chat, Kirsten asks Kelleen about her goals in developing Carvana’s Code of Conduct.

As Kelleen says:

“The Code was an opportunity to not only check a box — we certainly did — but to really weave in the values of the company, the voice of our CEO, and create something that would be used as a foundational piece going forward as our company matured and the compliance program matured.”

It was important to Kelleen and her team that Carvana’s Code provide actionable guidance for employees while reflecting the values and voice of the brand. The Code paved the way for Carvana’s evolving program of compliance policies, training, and communications.

Since 2017, Carvana has grown a lot, and so has their compliance program. Keep an eye out for more of Kirsten and Kelleen’s Zoom chat in the coming weeks to learn how Carvana has embraced experimentation and used targeted training and communications to grow their compliance function with the company.

Whether you’re looking to redesign your Code, take it digital, or get started from scratch, the Rethink Compliance team can help. Email us at to learn more about our Code and policy services or to set up a free consultation.