About PepsiCo
PepsiCo creates foods and drinks enjoyed by consumers more than one billion times a day in more than 200 countries and territories around the world. Their mission is to create joyful moments through their products and unique brand experiences; to be the best possible partner to their customers, driving game-changing innovation and a level of growth unmatched in the industry; to create meaningful opportunities for their associates and communities to build successful careers, and to build a stronger, more resilient future for PepsiCo and the communities where the company operates.
The company’s culture is shaped by behaviors that were historically outlined in The PepsiCo Way and are now reflected in One PepsiCo Way, which reflect the principles that sit at the heart of its ethics and compliance program.
The challenge
As a global organization with a large, diverse workforce, PepsiCo needed a consistent way to ensure that every new salaried employee understood what it means to “do business the right way”. The Global Code of Conduct outlines expectations for ethical behavior, respect in the workplace, fair dealing, and responsible engagement with customers, partners, and communities.
Previously, new hires took the same Code of Conduct course that was later assigned annually, resulting in some employees taking the course twice in a short period of time. At the same time, regulatory guidance, including from the U.S. Department of Justice, stressed the need for tailored, periodic training that truly integrates policies into day-to-day work.
PepsiCo sought a solution that would give new hires a clear, practical introduction to the Code and The PepsiCo Way, make complex topics digestible within a short onboarding window, engage a global audience across roles and languages, and demonstrate a strong, values-driven response to evolving regulatory expectations.
The solution
To help meet these needs, PepsiCo partnered with LRN to create the New Hire Code of Conduct Course and embed it as a mandatory part of onboarding for all newly hired salaried employees. Initially launched in 2020 and revamped in 2024, the 40-minute, scenario-based course introduces learners to PepsiCo’s Global Code of Conduct and key behaviors that were historically outlined in The PepsiCo Way and are now reflected in One PepsiCo Way, through five streamlined modules.
The course kicks off with a CEO welcome, which sets expectations and explains why the Code matters. Learners then move through core themes: Respect in the Workplace, Trust in the Marketplace, Fairness in Our Business Relationships, Honesty in Our Business Conduct, and Purpose in Our World, supported by text, visuals, and frequent knowledge checks.
Gamified questions award PepsiCo Globe Badges for correct answers and offer retries for incorrect ones, turning the experience into an interactive learning journey rather than a passive review. A dedicated Speak Up and non-retaliation module explains how to raise concerns and reinforces psychological safety, followed by a short assessment and certification step where learners confirm their commitment to the Code and disclose any potential conflicts of interest.
The course is available in 23 languages and is fully branded to feel “by PepsiCo, for PepsiCo,” and links directly to the company’s intranet for deeper policy exploration. In parallel, PepsiCo redesigned its broader Code strategy, so new hires receive this comprehensive course at onboarding, while annual Code training was broken into shorter, rotating modules to avoid duplication and keep ongoing learning timely and relevant.
Results
Since the revamped New Hire Code of Conduct Course went live in May 2024, about 12,000 new salaried employees have completed it. Although designed as a 40-minute experience, the average completion time is just 34 minutes, showing that the content is concise and focused while still covering essential topics.
The course is now a core pillar of PepsiCo’s ethics and compliance framework. It ensures that new hires receive a clear introduction to the Global Code and the previous, The PepsiCo Way, and understand expectations around respect, inclusion, product quality and safety, anti-bribery and fair competition, protection of assets and data, and PepsiCo Positive (pep+). It also helps employees know how and where to speak up without fear of retaliation and formally commit to following the Code and disclosing potential conflicts.
By combining gamification, real-world scenarios, and strong visual branding, PepsiCo has turned what could have been a dense policy read into an engaging, practical learning experience that new employees can understand, remember, and apply from day one.
Conclusion
PepsiCo’s New Hire Code of Conduct Course shows how a global company can make ethics and compliance both accessible and engaging for new employees, covering essential Code topics in a focused, time-efficient way while meeting regulatory expectations.
The 2024 introduction of gamification significantly boosted engagement and has paved the way for similar designs in new courses, including a Conflicts of Interest module to be launched in 2026. PepsiCo will continue to refine the training with annual updates, learner feedback, analytics, and regulatory guidance. This ongoing commitment will help foster and uphold their strong ethical workplace culture where employees are always encouraged to do what’s right, lead by example, and behave in a transparent and authentic way from the very beginning of their employment and throughout their careers.
