AI risk response and reporting frameworks are in place, but the challenge lies in employee utilisation
LRN, a global leader in the field of Ethics and Compliance (E&C), has announced the publication of the 2025 Code of Conduct Report (Japan Edition), a report specifically focused on the Japanese business environment.
In today’s world—marked by global disruption, rapid technological advancement, and growing workplace diversity—codes of conduct are no longer merely documents for legal compliance. They are dynamic frameworks that reflect a company’s values, culture, and ethical direction.
This report is based on a comprehensive review of the codes of conduct of 32 leading Japanese companies (including a comparative analysis with 2023 editions) and new survey data from 140 employees across Japan. It identifies key challenges and strategic opportunities for Japanese organisations compared with global standards.
Key Findings and Market Trends in Japan
- Responding to New Risks: Inclusion of AI Guidance
With the rapid evolution of AI technology, Japanese codes of conduct are beginning to address ethical risks related to AI—but adoption remains in its early stages.
- Increase in AI references: Mentions of AI in Japanese codes of conduct rose from 0% in 2023 to 13% in 2025.
- Lag in implementation: 87% of codes still do not include specific guidance on responsible AI use.
- Strengthening Reporting and Accountability: Institutional Support for Speak-Up Culture
- Greater visibility of reporting channels: Increased from 75% in 2023 to 97% in 2025.
- Explicit anti-retaliation measures: Increased from 63% to 83%, showing stronger protection for whistleblowers.
- Employee Awareness and Utilisation: The Challenge of Practical Effectiveness
- Growing adoption of web-based formats: 37% have online access, above the global average of 32%.
- Accessibility issues: Only 52% find their code easy to access, compared to 81% globally.
- Low reference usage： 49% of Japanese employees used their code when facing an ethical dilemma, versus 70% globally.
- Frequency of Updates: Falling Behind the Times
- Only 53% of Japanese companies updated their code of conduct in the past 2–3 years; 47% remain unchanged since 2023.
- Only 53% of Japanese companies updated their code of conduct in the past 2–3 years; 47% remain unchanged since 2023.
LRN’s Eight Elements of an Effective Code of Conduct
To make codes of conduct truly effective, LRN recommends focusing on eight key elements. For Japanese companies, improving accessibility is especially critical.
- Emphasis on purpose and values： Clearly reflect the company’s mission and core values.
- Speak-up culture： Establish a culture and system where employees can safely report concerns.
- Accessibility： Ensure easy, web-based access across all devices.
- Design and usability： Prioritise user experience (UX) and engaging design that encourages employees to read and use the code.
Conclusion: From Ideals to Implementation
While the structural and formal aspects of Japanese codes of conduct are improving, the true challenge lies in embedding them within organisations and using them to guide ethical decision-making. By evolving their codes into tools that are easy to use and trusted by employees, Japanese companies can strengthen their credibility as global corporate citizens and demonstrate ethical leadership.
About the Report
The 2025 Code of Conduct Report (Japan Edition) can be downloaded here:
https://lrn.com/ja/resources/code-of-conduct-report-2025-abridged-version
About LRN Corporation
LRN is the world's largest dedicated ethics and compliance company, educating and helping more than 30 million people each year worldwide navigate complex legal and regulatory environments and foster ethical cultures. As one of the Inc. 5000 Fastest-Growing Companies, LRN's growth and impact underscore our commitment to excellence and innovation in the advancement of ethical business practices. Our combination of practical analytics and software solutions, education, and strategic advisement helps companies translate their values into concrete practices and leadership behaviors that create sustainable, competitive advantage. LRN is the trusted long-term partner to more than 2700 organisations, including some of the most respected and successful businesses in the world.
