What does true ethics and compliance (E&C) maturity look like in 2025? That was the question at the heart of the London leg of the Global Masterclass Series hosted by LRN and the ICA. The event offered attendees an exclusive first look at the most comprehensive study of its kind: LRN’s 2025 Global Study on Ethics & Compliance Program Maturity. Drawing on responses from compliance professionals across various industries and regions, the study assesses E&C program maturity across six core dimensions: Culture, Resources & Board oversight, Written standards, Enforcement, discipline & incentives, Training & communication, and Risk assessment & reporting.
Meet the panel
- Ty Francis, MBE – Chief Advisory Officer, LRN. A globally recognized ethics expert with a background at the New York Stock Exchange and deep experience shaping compliance trends.
- Rebecca Mayfield – Global Compliance Director, Merlin Entertainments. A creative compliance leader working across diverse global attractions.
- Luciane Mallman – Senior Compliance Counsel, ByteDance/Tik Tok. ICA-certified, with prior roles across tech, aviation, real estate, and law.
- Charlie Patrick – Partner, Forensic Risk Alliance. Specialist in investigations and monitorships, including the high-profile Rolls-Royce DPA.
Moderated by Pekka Dare, President of the International Compliance Association, the session included lively breakouts and an honest exchange of experiences between compliance leaders.
This article recaps the most important insights, practical recommendations, and expert commentary from the event’s dynamic panel.
The maturity map: A mixed picture
Chief Advisory Officer at LRN, Ty Francis MBE, opened the session with a powerful overview of the research methodology and findings. Among the six key dimensions, “Board Oversight & Resources” scored the highest, indicating solid governance structures. However, “Culture” ranked lowest, highlighting the persistent challenge of making compliance meaningful across all levels of the organization.
Key findings from the study include:
- Only 31% of companies evaluate ethical behavior in performance reviews—despite 76% conducting ethics surveys.
- Culture measurement is often conflated with HR engagement surveys that lack anonymity or relevance to ethical conduct.
- Training comprehension is alarmingly undermeasured, and misconduct data is rarely fed back into program improvements.
- Interactive codes of conduct and predictive data usage are growing trends—but adoption is uneven.
Key themes from the discussion
1. Culture is still the weak link
Culture-driven compliance still lags in the middle—while 76% of organizations conduct annual ethics or culture assessments, only 31% formally evaluate ethical behavior through performance reviews.
Despite being the bedrock of mature programs, culture remains the most under-measured and misunderstood dimension. Many companies rely on HR tools that don’t reflect ethical risk or psychological safety. The panel stressed the need for more authentic, anonymized, and purpose-built culture diagnostics.
Luciane advocated for stronger collaboration between compliance and HR, especially when it comes to culture surveys. She shared her experience launching compliance frameworks in fast-scaling companies and stressed the need for tailored engagement with middle management.
“We must make ourselves relevant—be visible, be involved, and help shape the survey questions that define our culture,” she said.
2. Middle management should be empowered
Repeatedly, the “tone from the middle” came up as a gap. While leadership articulates values, these often get diluted or deprioritized by operational and commercial pressures. Empowering and equipping managers to lead ethically was a recurring recommendation.
Charlie drew attention to what he called the “Measurement Gap”—the widening disconnect between how senior leaders and employees perceive the culture and effectiveness of compliance programs.
“Senior leaders believe the program is great. But the further down you go, the worse the perception. That’s a huge risk.”
Luciane agreed, suggesting that organizations map compliance KPIs into middle manager objectives and embed these into the company’s risk assessment frameworks.
3. Codes of Conduct must be dynamic
Codes of conduct have seen some positive evolution. The study found that 45% of companies now update their code annually—up from just 11% in 2014.
But as Ty pointed out, “An annual refresh means little if it’s just swapping out the CEO’s welcome message.”
He pushed for codes to be interactive, data-rich, and tailored to user needs—especially for global or decentralized workforces.
He also warned against relying on static documents no one reads. The best practice? Make them searchable, interactive, and data-rich. Monitor which sections are accessed (or ignored) and use that intel to pre-empt risk.
Rebecca’s recommendation? Be creative. Embed links in SharePoint tickers, use app pop-ups, and create memorable campaigns. Ty reinforced that this isn’t about gimmicks—it’s about enabling informed decisions when it matters.
4. Training and trend data: Untapped potential
The study found that only 37% of organizations track misconduct trends after training, and just 44% measure training comprehension at all.
Rebecca shared a simple but effective tactic: turning training completion stats into a league table among executives. “Competitive spirit did the rest,” she noted.
Ty urged organizations to focus on comprehension, not completion—and to feed back what’s learned into program design.
Rebecca went on to emphasize the importance of emotional connection in compliance communications and training. Reflecting on a theme park ad that moved her emotionally, she posed a provocative question: “Should compliance messaging make you feel something too?”
5. Investigations: Still stuck in spreadsheets
More than one-third (35%) of organizations still manage investigations using spreadsheets, and fewer than 30% deploy a cross-functional investigation team.
Excel isn’t the enemy, manual, siloed tracking of misconduct investigations is—wasting time and obscuring systemic risks. Ty described situations where investigations were hidden in HR folders for months, preventing other functions from spotting systemic issues. He went on to add that regulators are no longer satisfied with static, isolated data.
Charlie brought the investigative lens, warning against siloed investigations and manual case tracking, urging organizations to adopt unified systems that link data across departments.
Final thoughts
This masterclass didn’t just highlight gaps—it pointed to solutions. Culture may remain elusive, but tools exist to illuminate it. Training may go unchecked, but data can change that. The message was clear: ethics and compliance teams must think creatively, act collaboratively, and never stop asking “What’s next?”
For those ready to explore the findings in more depth, you can download the full report from LRN here.