TRACE member intermediaries are required to have or adopt a clear written policy addressing bribery, extortion, and kickbacks. If a member candidate does not have a written code of conduct, TRACE will help the candidate to draft and adopt one.

Many intermediaries adopt the TRACE model Code of Conduct, which specifically addresses local and foreign laws, bribery and facilitating payments, kickbacks, extortion, conflicts of interest, political and philanthropic contributions, gifts, hospitality and entertainment, accounting and reporting requirements, and communication of and training for the code.