Several approaches such as top-down, bottom-up approach were used by MNEs to regulate labor practices, however little is known about the approaches taken by the actual implementers who execute these policies. This research was designed to explore policy implementers'/managers' approaches on CoC implementation within the context of Indian apparel export houses. A qualitative study involving semi-structured interviews was conducted. Eight participants from North India were interviewed. Data was transcribed and analyzed. Overall, six themes surfaced surrounding the (a) meaning, (b) formulation, and (c) implementation of CoCs. These approaches were then interpreted from the lenses of the managers/owners' psychological orientation: convergent or divergent thinking. The convergent thinkers perceived CoC as a rulebook set by the company executives and government where policies were implemented as set procedure. In contrast, divergent thinkers viewed CoC as a growth plan emphasizing on future visioning techniques, open discussion and greater flexibility in their business operations.