Corporate Codes lag in addressing emerging business risks, leaving employees without proper guidance on AI, trade, security and more
An organization can report near-perfect code of conduct acknowledgment while many employees rarely use the code to make decisions. Employees receive it, certify that they have read and understood it, and complete the required process. The organization records the result and reports the completion rate to the board.
That process matters. But completion is not the same as effectiveness—and treating it that way can create a false sense of success.
What LRN’s latest research shows
LRN’s 2026 Code of Conduct Report shows just how widespread formal acknowledgment has become. 95% of employees surveyed say their organization requires them to certify or acknowledge the code, and for 68% of those employees, that is an annual requirement. In other words, organizations have become very good at getting the code in front of employees and documenting that they received it.
The more important question is what happens after employees click “acknowledge.”
Acknowledgment measures reach. Engagement measures relevance.
The distinction becomes clear when we look at how employees actually use the code.
Only 63% of employees say they have used their company’s code as a resource, down from 70% in 2025. And outside formal code training, just 24% use the code often or very often. By contrast, 43% say they rarely or never turn to it outside training.
Those numbers point to a gap between formal activity and practical engagement.
An acknowledgment confirms that an employee completed a required step. It does not show whether that employee will return to the code six months later when facing a conflict of interest, a difficult customer request, a question about confidential information, or an unfamiliar ethical issue.
This distinction echoes a broader lesson from LRN’s 2026 Ethics & Compliance Program Effectiveness Report: activity metrics provide only a limited view of effectiveness. The same principle applies to the code.
Ask better questions about your code
If acknowledgment rates are only the starting point, what should ethics and compliance teams measure instead?
Start with whether employees return to the code when faced with an ethical dilemma or difficult decision. If employees see it only during onboarding, annual certification, or mandatory training, the code risks becoming an annual compliance event rather than an everyday resource.
Then ask whether employees can find what they need once they get there. The 2026 research shows that nearly one in four employees say their code is too long or difficult to navigate, while about one in five say it lacks practical guidance. More than half report challenges (for example, it’s too long, or it’s difficult to quickly find information) when using the code.
A practical measurement framework should look beyond certification rates and track indicators such as:
- Repeat use: visits to the code outside onboarding, training, and certification periods.
- Findability: whether searches and navigation lead employees to relevant guidance quickly.
- Practical application: employee confidence in applying the code to realistic scenarios.
- Connections to help: use of policy links, reporting channels, training, and other resources reached through the code.
- Employee experience: feedback on the code’s clarity, navigation, and usefulness in making decisions.
Together, these measures shift the focus from whether the organization delivered the code to whether the code delivers value to employees.
Design your code for the moment of need
The research also provides clues about how organizations can close the engagement gap.
Most codes have some of the basic building blocks of good design. 83% of analyzed codes have a good layout, 80% direct employees to related policies, and 66% include a table of contents. But features that help employees apply the standards to everyday decisions are much less common: only 39% include an ethical decision-making model and 29% include scenario-based questions and answers (Q&As).
That matters because employees usually do not reach for the code simply to reread a rule. They reach for it because they have a question.
Should I accept this gift? Can I share this information? What should I do if a customer asks me to do something that feels wrong? Where do I go if I need to raise a concern?
A useful code is designed for those moments. It gets employees to the relevant guidance quickly, helps them apply principles to the situation in front of them, and gives them a clear next step when the answer is not obvious.
Move from completion to impact
None of this means organizations should abandon annual acknowledgment. Formal certification remains an important part of code governance, and the 2026 findings show that organizations have successfully institutionalized it.
But 95% acknowledgment and 63% resource use are measuring two very different things.
One tells you whether employees completed a process. The other shows whether the code has a life beyond that process.
For ethics and compliance leaders, that should change the definition of success. The goal is not simply to get employees through the code once a year. It is to create a resource they know how to find, understand how to use, and choose to return to when a difficult decision arises.
Acknowledgment tells you the code reached employees. Engagement tells you whether it matters. What does your organization measure after employees click “acknowledge”?
Download LRN’s 2026 Code of Conduct Report, The culture behind the code: Turning standards into everyday decisions.
