LRN recently hosted “Bridging the Effectiveness Gap: Practical Lessons from the 2026 PE Report,” a discussion focused on findings from its 12th Annual Program Effectiveness Report. The research examines how ethics and compliance programs are performing globally — and where meaningful effectiveness gaps persist.
The panel featured:
- Ty Francis, MBE, Chief Advisory Officer at LRN
- Eric Morehead, Director of Advisory Services at LRN
- Jen-Larie Tumminello, Governance, Risk and Compliance Executive at TD
Drawing on global survey data and practitioner insight, the conversation explored what differentiates high-impact compliance programs from those struggling to demonstrate measurable results.
Several themes emerged: underused analytics, ongoing third-party risk exposure, perception gaps between leadership and employees, and increasing pressure to prove program impact.
Compliance Program Effectiveness: Moving Beyond Activity Metrics
One of the clearest findings from the 2026 report is that many organizations still measure activity rather than effectiveness.
As Ty noted:
“The data’s showing only 34% use analytics for evaluation, and 29% employ analytics to assess their program effectiveness. So, less than a third of companies are using all this rich data they have.”
Training completion rates and policy attestations remain common benchmarks. High-impact programs, by contrast, are more likely to integrate multiple data sources and analyze trends to assess behavioral impact — not just participation.
Third-Party Risk and Due Diligence: A Clear Maturity Divide
Third-party and supply chain oversight remains a vulnerability for many organizations.
Eric emphasized:
“This number, 27% adoption, on due diligence, is really shocking.”
When broken down by program maturity:
- High-impact programs: 51% adoption
- Medium-impact programs: 22%
- Low-impact programs: 15%
As Ty observed:
“Low-impact programs… are adopting at 15%, which is, you know, three times lower than high-impact programs that are still only 51%.”
The data suggests that stronger third-party due diligence is closely tied to overall program effectiveness.
Speak-Up Culture and Leadership Trust as Measurable Indicators
A defining strength of the report is its dual-lens approach — surveying both compliance professionals and employees. This comparison revealed persistent perception gaps, particularly around culture and psychological safety.
Jen distinguished between structural metrics and cultural reality:
“You can measure training completion and policy coverage as hygiene metrics… But culture, however, is measured by whether employees believe leaders are consistently acting with values… whether people feel safe speaking up.”
High-impact programs are characterized not just by controls, but by employee confidence in leadership integrity and speak-up protections.
The Middle Management Gap in Ethics and Compliance
The discussion also highlighted a frequent breakdown point: middle management.
“The messaging that gets to middle management is not making it past them. So, employees are seeing gaps between policy and practice.”
When frontline managers do not consistently model values, employees quickly detect the disconnect. That perception gap directly affects trust — and program credibility.
From Compliance Measurement to Visible Accountability
The panel returned repeatedly to the importance of closing the loop between data and action.
Collecting insights is not enough. Employees must see consistent enforcement, clear responses to concerns, and leadership alignment with stated values.
The Future of Ethics and Compliance: A Reset Around Trust
The webinar concluded with a broader reflection on where compliance is heading.
“This kind of marriage of ethics compliance—it won’t come from tech alone. It’s going to be a reset of trust between leaders and employees, organizations and regulators, and the people and the systems they’re building together.”
The 2026 Program Effectiveness Report underscores a clear shift: stakeholders are no longer satisfied with evidence of activity. They expect measurable cultural impact, stronger third-party oversight, and visible accountability.
Organizations that can demonstrate those outcomes — not just document effort — are the ones truly bridging the effectiveness gap.
