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AI ethics gaps persist in company codes despite greater access

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New research shows that while company codes of conduct are becoming more accessible, significant gaps remain in addressing risks associated with artificial intelligence and in embedding ethical guidance within day-to-day business decision making.

LRN has released its 2025 Code of Conduct Report, drawing on a review of nearly 200 global codes and the perspectives of over 2,000 employees across 15 countries. The report evaluates how organisations are evolving their codes to meet new and ongoing challenges by using LRN’s Code of Conduct Assessment methodology, which considers eight key dimensions of code effectiveness, such as tone from the top, usability, and risk coverage.

Emerging risks unaddressed

One of the central findings is that while companies are modernising the structure and usability of their codes, a clear shortfall exists in guidance around new risks, particularly those relating to artificial intelligence. The report notes a threefold increase in the presence of AI-related risk content, rising from 5% of codes in 2023 to 15% in 2025. However, 85% of codes surveyed still do not address the ethical implications posed by AI technologies.

“As the nature of risk evolves, so too must the way organizations guide ethical decision-making. Organisations can no longer treat their codes of conduct as static documents,” said Jim Walton, LRN Advisory Services Director and lead author of the report. “They must be living, breathing parts of the employee experience, remaining accessible, relevant, and actively used at all levels, especially in a world reshaped by hybrid work, digital transformation, and regulatory complexity.”

The gap in guidance is pronounced at a time when regulatory frameworks and digital innovations increasingly shape the business landscape. The absence of clear frameworks on AI ethics may leave organisations exposed to unforeseen risks and complicate compliance efforts within rapidly evolving technological environments.

Communication gaps

The report highlights a disconnect within organisations regarding communication about codes of conduct. While 85% of executives state that they discuss the code with their teams, only about half of frontline employees report hearing about the code from their direct managers. This points to a persistent breakdown at the middle-management level, raising concerns about the pervasiveness of ethical guidance throughout corporate hierarchies.

Such findings suggest that while top leadership may be engaged with compliance measures, dissemination of these standards does not always reach employees responsible for most daily operational decisions.

Hybrid work impact

The report suggests that hybrid work environments have bolstered employee engagement with codes of conduct. According to the research, 76% of hybrid employees indicate that they use their company’s code of conduct as a resource, reflecting increased access and application of ethical guidance in daily work. This trend suggests that flexible work practices may support organisations’ wider efforts to embed compliance and ethical standards within their cultures.

Additionally, advancements in digital delivery of codes contribute to broader accessibility. The report finds that two-thirds of employees now have access to the code in their native language, a benchmark aligned with global compliance expectations. Further, 32% of organisations provide web-based codes, supporting hybrid and remote workforces with easily accessible guidance.

Foundational risks remain central

Despite the growing focus on emerging risks, companies continue to maintain strong coverage of traditional issues within their codes. Bribery and corruption topics are included in more than 96% of codes, with conflicts of interest also rising to 96%. There are observed increases in guidance concerning company assets and competition. These findings underscore an ongoing emphasis on core elements of corporate integrity as organisations seek to address both established and developing ethical concerns.

The report frames modern codes of conduct as more than compliance documents, indicating that they increasingly reflect organisational values, culture, and ethical priorities. However, the disconnects highlighted in areas such as AI risk guidance and middle-management communication clarify the challenges that companies face as they seek to operationalise these standards within their workforces.

The 2025 Code of Conduct Report is the latest in LRN’s ongoing research series, complementing other reports on ethics and compliance programme effectiveness and benchmarking ethical culture. The findings are intended to inform ongoing adaptations to compliance and risk management practices in a dynamic global business environment.



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Ethics & Policy

Leadership and Ethics in an AI-Driven Evolution

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Leader Forum: Leadership and Ethics in an AI-Driven Evolution
















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