Their whole CoC is a roundabout way of saying: Follow the policies! Obey the law!

It doesn't suggest that Employees should ever exercise their own moral judgement without first contacting Ethics & Compliance.

>"Don't be evil"

Thankfully (for Google), that phrase is completely vapid and meaningless.

Also thankfully (for Google), self-enforced codes of conduct are vapid and meaningless.

Edit (in an effort to be more constructive): I think it's important to distinguish corporate posturing from actual, meaningful intent. I see no reason to consider Google's CoC as anything but the former.