This thesis analyzes the transfer process of a code of conduct (COC) within an Austrian based multinational enterprise (MNE). Potential challenges, accompanying this transfer process, will be outlined and linked to suggestions, mentioned in already existing literature. However, the purpose of this thesis is to shed light on Austrian businesses and to address the issue of cross-cultural differences. Especially when introducing a standardized document such as the COC. In order to analyze and evaluate a COC, which is in line with the intra-company values, a qualitative approach was chosen: Namely semi-structured interviews in combination with an analysis of the corporate website and the already existing COC. The data collected supports the theoretical assumption, that the main challenges within the transfer emerge during the implementation process, local adaptations, and the degree of the code embeddedness. Additionally, language is considered to be a main challenge. As literature suggests, translations are a crucial element, since they can change the meaning of a message completely if not done correctly. Moreover, distinct languages complicate the process, since it is more difficult to assure whether the audience understood the content correctly. Beyond doubt, cross-cultural differences influence this fact significantly. Local adaptations to COCs are suggested by literature but proof to be different in a practical setting. The findings show, that local adaptations are not permitted if they would violate the code. Furthermore, a COC is meant to be global; thus, adaptations would make the code more decentralized. Nevertheless, the code has to be adapted at least partly to norms such as the legal framework of a country. While addressing the challenges that emerge during the transfer process, constant trainings, feedback-rounds, and updates are necessary to embed the code into the entire organization.