That will probably mean a lot of programmers get the brunt of the punishment for "following orders".
If it's company policy then giving such orders would be an infringement.
It would be up to the top management, preferably the board, to lay down policy; the costs of this are going to end up as sufficient to have board level visibility. It's then up to the board to ensure that the blame arrives in the right place or, failing that, the employment tribunal.