LRN research find less than 1 in 10 corporate Codes of Conduct address AI usage and less than half provide guidance on ethical decision making

Corporate Codes lag in addressing emerging business risks, leaving employees without proper guidance on AI, trade, security and more   

NEW YORK, NY – October 6, 2026 – LRN Corporation, a global leader in ethics and compliance solutions, released its annual 2026 Code of Conduct Reports, The culture behind the code: Turning standards into everyday decisions. The report reveals a widening gap between the role organizations expect their codes of conduct to play and the support they actually provide employees, particularly as the rapid adoption of AI creates new governance challenges and increasingly complex ethical considerations. While nearly every organization offers a code, fewer employees are using it as a practical resource for everyday decision-making, according to LRN’s new data which reports only 63% of employees say they have used their code as a workplace resource, down from 70% in 2025.

This year’s findings, based on an analysis of more than 1,100 codes of conduct and a survey of 2,000 full-time employees across 15 countries, also suggest that many codes have not kept pace with today's rapidly evolving business environment. As organizations navigate the rapid adoption of artificial intelligence, geopolitical uncertainty and increasing regulatory complexity, corporate codes lag in providing proper guidance on emerging business risks, meaning employees often lack the guidance they need to make sound ethical decisions in real-world situations.

In fact, LRN's analysis found that only 9% of corporate codes explicitly address AI and technology use, fewer than 40% address the handling of competitive intelligence, security or crisis, and only about half address evolving labor law and trade-related issues. The research highlights the need for organizations to modernize their codes so they remain practical, accessible, and relevant in a changing risk landscape.

"Organizations are asking employees to navigate increasingly complex decisions involving AI, data, security, and global business risks, but many of the codes of conduct in use today were not designed for that reality," said Bob Lemmond, CEO of LRN. "The strongest codes aren't just collections of rules. They help employees apply company values to real-world situations and help them make ethical decisions when the right path isn't always obvious. The strongest codes are not treated as standalone resources. Instead, they are embraced as an integrated element of how an organization shapes its culture – from embedding the code into employee education, to ensuring leaders model expectations for workplace behavior, to cultivating a culture where employees feel comfortable speaking up.”

LRN’s 2026 Code of Conduct report is the latest in LRN’s on ongoing study of ethics and compliance program effectiveness, the business impacts of ethical culture, and best practices for inspiring values-based decision making in the workplace. LRN’s Code of Conduct Report examines eight dimensions of code effectiveness, including tone from the top, purpose and values orientation, applicability and administration, reporting and non-retaliation, risk topics, knowledge reinforcement, usability, and look and feel.

Additional findings from LRN’s 2026 Code of Conduct report include:

• Formal code compliance efforts are not translating into real-world use: Nearly every employee is required to acknowledge or certify their organization's code, yet only 63% have used it as a workplace resource, down from 70% in 2025. Just one in four employees use it regularly outside of training.
• Employees want practical guidance, but most codes don't provide it: Only 40% of codes include an ethical decision-making framework, and fewer than one-third provide scenario-based guidance. Nearly 1 in 4 employees say their code is too long or difficult to navigate, while almost 1 in 5 say it lacks practical guidance for real situation..
• Employees are losing confidence in speaking up: While 97% of codes provide reporting resources, only 42% explain what happens after a report is made. Employee confidence is declining, with only 66% reporting they feel confident they can report misconduct without retaliation, down from 71% in 2025.
• Manager reinforcement of the code is declining: Only 61% of employees say their manager talks about the code, down from 67% in 2025. The gap is even more pronounced across levels, with 77% of executives hearing about the code from managers compared with fewer than half of frontline administrative and technical employees.
• Gen Z is struggling most with today's codes: One-third of Gen Z employees (34%) say their code is too long or difficult to navigate, compared with just 16% of Gen X employees and roughly 10% of Boomers. Digital PDFs remain the dominant format, available to 65% of employees, while 38% have access through a website, which is an increase of almost seven percentage points from 2025.

Informed by its proprietary benchmark data and best practice insights, LRN recommends organizations treat the code as a gateway to the broader ethics and compliance program by connecting it to related policies, employee education, reporting resources, and decision-making tools.

“The strongest codes do not force organizations to choose between substance and usability,” said Jim Walton, LRN Advisory Services Director and lead author of the report. “They provide enough depth to address the risks employees face while making that guidance easy to navigate and apply. That balance - supported by leadership, manager reinforcement, and trust around speaking up - is what helps a code become part of an ethical culture rather than an annual compliance exercise.”

To download the full 2026 Code of Conduct Report, visit here.

About LRN’s Reports

The 2026 Code of Conduct Report 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 the Program Maturity Report. Combined, LRN industry research provides unparalleled insights into best practices, benchmarks, and innovative strategies shaping the future of compliance programs.

About LRN: Inspiring Principled Performance

Since 1994, LRN has been a trusted partner to organizations committed to operating at the highest standards of ethics, responsibility, and performance. Today, more than 2,500 organizations around the world, and their people, rely on LRN's AI-powered ethics and compliance platform, education, analytics, and expert advisory services to navigate an increasingly complex legal and regulatory landscape and foster ethical cultures. By helping organizations embed ethics and compliance into everyday practices and decision-making, LRN enables organizations to build trust, reduce risk, and create lasting competitive advantage through principled performance. Learn more at www.lrn.com.