LRN Research Exposes Gaps in Ethical Culture, Enforcement, and Risk Management
The data from our latest study shows progress, but also offers a call to action for organizations to do more to embed ethical behavior into day-to-day decision-making, especially at the middle management level.
'As organizations face increasing scrutiny, rising complexity, and fast-evolving risks, the strength and sophistication of a company's E&C program becomes a true differentiator,' said Kevin Michielsen, CEO of LRN Corporation. 'The data from our latest study shows progress, but also offers a call to action for organizations to do more to embed ethical behavior into day-to-day decision-making, especially at the middle management level.'
Drawing on insights from global benchmarking and survey data using LRN's proprietary Program Maturity Assessment (PMA), the report evaluates the maturity of E&C programs across six core dimensions: Culture, Written Standards, Enforcement & Incentives, Risk Assessment, Training & Communication, and Resources & Board Oversight. The study reveals that while organizations are updating codes of conduct and expanding board-level oversight, deep gaps remain in middle management engagement, culture-building, enforcement, and risk assessment.
Key Findings:
Cultural Alignment Underdeveloped: Although 76% of companies conduct annual ethics or culture assessments, only 31% evaluate ethical behavior in performance reviews. Just 15% report having a strong 'tone in the middle,' with manager training and accountability notably under-resourced, including 20% offering no manager-specific training at all. This lack of investment risks reducing corporate values to empty rhetoric, rather than lived practice.
Codes of Conduct Frequently Updated, Not Fully Embedded: 71% of organizations revise their Code of Conduct at least every three years, with 45% doing so annually, up from 11% a decade ago. However, many still struggle to integrate these standards into real-world decisions and ensure they're seen as relevant, actionable, and accessible to employees across functions and geographies.
Training and Impact Measurement Gaps Persist: Only 44% of organizations assess training comprehension, and just 37% track misconduct trends after training. Many programs focus on completion rates rather than outcome-based metrics, limiting their ability to demonstrate true effectiveness.
Investigations Remain Manual and Fragmented: Over 35% of organizations still use spreadsheets to track misconduct cases, and fewer than 30% use cross-functional investigation teams, raising serious concerns about data integrity, auditability, and consistency.
Risk Assessment Practices Lack Depth: Only 19% of organizations include talent management risks in their compliance risk assessments, and fewer than one-third evaluate reputational or ethical misconduct risk comprehensively.
'Organizations that embed ethics into how they lead, manage, and reward people are positioning themselves for long-term resilience and trust,' said Ty Francis, MBE, Chief Advisory Officer at LRN Corporation. 'Organizations may have the right policies on paper, but without investment in middle management, integrated systems, and accountability structures, they will struggle to translate principles into practice.'
The 2025 Global Study on E&C Program Maturity offers a clear roadmap for building resilient, values-driven organizations based on insights from a diverse, global pool of compliance professionals. Organizations must reinforce manager accountability to ensure that ethical values are consistently modeled and upheld at every level. They should modernize investigations by adopting integrated tools, enhancing speed, transparency, and credibility, and closing the measurement gap by rigorously evaluating organizational culture, training effectiveness, and ethics-based decision-making.
To download the full 2025 Global Study on Ethics & Compliance Program Maturity, visit here.
The 2025 Global Study on Ethics & Compliance Program Maturity is the latest installment in LRN's decade-long research series of surveys and analyses that track data points from organizations across the world. This research complements other LRN ongoing studies, including the Ethics & Compliance Program Effectiveness Report, the Benchmark of Ethical Culture Report, and Code of Conduct Report. Combined, LRN industry research provides unparalleled insights into best practices, benchmarks, and innovative strategies shaping the future of compliance programs.
About LRN Corporation
LRN is the world's largest dedicated ethics and compliance company, educating and helping more than 30 million people each year worldwide navigate complex legal and regulatory environments and foster ethical cultures. As one of the Inc. 5000 Fastest-Growing Companies, LRN's growth and impact underscore our commitment to excellence and innovation in the advancement of ethical business practices. Our combination of practical analytics and software solutions, education, and strategic advisement helps companies translate their values into concrete practices and leadership behaviors that create sustainable, competitive advantage. LRN is the trusted long-term partner to more than 2700 organizations, including some of the most respected and successful businesses in the world.
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