The Code of Conduct remains one of the most powerful tools organizations have to communicate values, guide decision-making, and build trust across the workforce. In LRN’s recent webinar, 2025 Code of Conduct Report: Employee Insights & Emerging Trends, panelists Jim Walton (LRN), Christopher Annand (Cargill), and Deborah Spanic (Clarios) shared how companies are rethinking their Codes and the areas where there is still room to grow.
AI and Emerging Risks
One of the biggest shifts since 2023 is the inclusion of artificial intelligence. References to AI in Codes have tripled, from just 5 percent in 2023 to 15 percent in 2025. While this shows a growing awareness of AI-related risks, 85 percent of Codes still do not address it, which leaves a wide gap to fill.
During the session, panelists pointed to companies already making progress. British Telecom includes high-level principles around responsible technology use, while Colgate-Palmolive takes a more detailed approach by outlining specific guidance. Both examples highlight how important it is to give employees clear direction on emerging technologies so they can apply them responsibly in their day-to-day work.
Accessibility and Usability
The report also highlights encouraging steps toward making Codes easier to use. Two-thirds of employees now say they can access their Code in their native language, which is essential for global organizations. More Codes now feature clear navigation, links to related policies, and decision-making models.
Christopher Annand explained that at Cargill, brevity is key. Their Code is designed to serve as a “concierge,” staying concise and straightforward while pointing employees to more detailed resources when needed. This approach keeps the Code manageable for employees while still providing the depth they need if questions arise.
Engagement and Communication
Employee engagement with Codes of Conduct is also rising. In 2025, 76 percent of employees reported using their Code as a resource, compared with 67 percent the year before. Hybrid work likely plays a role here, with Codes becoming easier to access online.
At the same time, the data shows a gap in communication. While most executives refer to the Code regularly, fewer than half of frontline employees say they hear about it from their managers. Deborah Spanic noted that closing this “tone from the middle” gap is critical. Managers are the bridge between leadership and employees, and when they actively use the Code in conversations, it helps make ethics and values part of the everyday culture.
Insights from Practice
Our panelists also shared practical ways to make Codes more effective:
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Decision-making models: Both Cargill and Clarios have added frameworks that help employees navigate tough choices with confidence.
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Confidentiality in public Codes: To protect sensitive information, companies typically require credentials to access internal policies linked from public Codes. This keeps Codes transparent while safeguarding what needs to remain private.
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Training and reinforcement: At Cargill, new hires complete compliance training within their first 30 days and are then enrolled in annual refresher courses. The company is also exploring the idea of tying compliance metrics, such as on-time training completion, to performance reviews to further strengthen accountability.
Looking Ahead
The 2025 Code of Conduct Report shows progress and momentum. Organizations are updating their Codes more often, making them easier to use, and beginning to address new risks. Yet the real challenge is ensuring that these Codes are not just documents, but living resources that are accessible, practical, and reinforced by leaders at every level.
For a deeper look at the data and to hear more from our panelists, we invite you to:
👉 Watch the on-demand webinar
👉 Download the full 2025 Code of Conduct Report
Stay connected with more LRN events by visiting our Events page.
