The correct answer is C. A code of business ethics and conduct is most effective when it clearly communicates the organization’s values, expected behavior, and major compliance risks, including bribery, conflicts of interest, gifts, hospitality, facilitation payments, and dealings with third parties. Its purpose is not merely to impose management’s expectations, but to guide ethical decision-making across the organization. Option A is too one-sided and does not reflect tone at the top or mutual accountability. Option B is too narrow because anti-corruption obligations extend beyond shareholders to regulators, customers, employees, business partners, and the public. Option D is unrealistic because no code can address every possible ethical situation; it should provide principles, reporting channels, and escalation guidance.

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