How confident are you that your ethics and compliance programme is helping your organisation navigate today’s risks? Economic uncertainty, geopolitical conflict, supply chain disruption, stakeholder activism, and increased scrutiny by government regulators present significant challenges for the road ahead. But new data from LRN’s 2023 Ethics & Compliance Programme Effectiveness Report shows that programme effectiveness reinforces corporate resilience in challenging times.

Based on a survey of nearly 1,860 ethics and compliance professionals at companies and organisations worldwide—one of the largest surveys of its kind—this annual report aims to help businesses:

  • Access important benchmarks to evaluate and enhance their own compliance programmes.  
  • Learn what worked, what needs improvement, and why some E&C programmes excelled while others did not.    
  • Answer a critical question posed by government regulators: Does their compliance programme work in practice, not just on paper?  

This year’s report determines the critical differentiators that make some E&C programmes more effective than others. These differences—and the best practices embraced by high-performing programmes—are even more critical to understand than before. Let’s dig into eight key insights from the report (which you can read in full here) and what they mean for improving ethics and compliance programme effectiveness in 2023.

Ethical culture is getting stronger across compliance programmes



Ethics and compliance programmes emerged from the COVID-19 pandemic with strengthened ethical culture. According to the report, 85% of respondents stated that their ethical culture is stronger as a result of their experiences meeting challenges over the past year. Even more reported that ethics and compliance considerations were taken into account in meeting these challenges. And 84% reported that their organisations relied upon values, rather than rules, to motivate employees to do the right thing.

Ethical leadership matters to compliance programme effectiveness 



Tone at the top is always a critical factor in the success of any E&C programme, but managers are the “first responders” when it comes to incorporating ethics into the workplace. More than half of the report’s respondents gave their executives and managers high marks for taking ethical considerations into account in business decisions, managing risk, and balancing employee needs with business goals and priorities. 

The need for good data and analytics has skyrocketed for E&C programmes



Ongoing evaluation via operational data and analytics, particularly in light of changing risks, is a key component of improving programme effectiveness and emphasised frequently by regulators. The 2023 report found that use of employee surveys, engagement with ethics and compliance resources, root cause analysis, and other metrics to assess programme effectiveness increased by one-third over LRN’s 2023 report results, highlighting the importance of continuous review and improvement. 

Effective E&C programmes influence business outcomes



On the whole, effective ethics and compliance programmes are impactful when it matters. Encouragingly, over half of the report’s respondents stated that E&C factors and risks led to their organisation substantially modifying or abandoning a business initiative. And high-performing E&C programmes were 30% or more likely than those ranked as less effective to impact important business decisions, relevance, and continuous evaluation and improvement.

Engagement with E&C improves when programmes keep things simple and accessible



Ongoing enhancements designed to improve programme impact with employees are a defining difference between high-performing and less-effective E&C programmes. More than half of high-performing ethics and compliance programmes improved their engagement with employees using interactive codes of conduct, improved and more flexible training, and simplified policies.

Employee ethics are a greater factor in professional advancement



According to the 2023 report, more and more organisations—over 60% of those surveyed—have formal requirements that executives’ and employees’ ethical behaviour is taken into account in performance evaluations, promotion, bonus awards, and hiring for key control functions.

There is also growing emphasis on consequences of ethical misconduct



LRN’s report found that 56% of all respondents stated that their organisation’s policies provided for clawback of bonuses, incentives, and compensation in the event of misconduct—an area emphasised by regulators and a “must have” best practice. 

Inadequate internal systems are the biggest obstacle to programme effectiveness worldwide



Ethics and compliance programmes worldwide are hitting a wall when it comes to improving their reach, employee engagement, and use of data metrics. In order to meet the challenges of remote and hybrid work, platforms need to be multi-functional to help E&C teams do their work efficiently, particularly in light of the staff shortages and budget constraints (also cited above). 

The key takeaway

These insights and others from the 2023 Ethics & Compliance Programme Effectiveness report validate a central lesson from LRN’s ongoing research: that the most effective programmes—those taking a values-based approach to governance, culture, and leadership—correlate strongly with reduced risk and better business outcomes. To learn more about how you can reinforce your programme—and organisational—resilience, download the report today.


Susan Divers
Senior Advisor

Susan Divers is a senior advisor with LRN Corporation. In that capacity, Ms. Divers brings her 30+ years’ accomplishments and experience in the ethics and compliance area to LRN partners and colleagues. This expertise includes building state-of-the-art compliance programmes infused with values, designing user-friendly means of engaging and informing employees, fostering an embedded culture of compliance, and substantial subject matter expertise in anti-corruption, export controls, sanctions, and other key areas of compliance.


Prior to joining LRN, Mrs. Divers served as AECOM’s Assistant General for Global Ethics & Compliance and Chief Ethics & Compliance Officer. Under her leadership, AECOM’s ethics and compliance programme garnered six external awards in recognition of its effectiveness and Mrs. Divers’ thought leadership in the ethics field. In 2011, Mrs. Divers received the AECOM CEO Award of Excellence, which recognised her work in advancing the company’s ethics and compliance programme.


Mrs. Divers’ background includes more than thirty years of experience practicing law in these areas. Before joining AECOM, she worked at SAIC and Lockheed Martin in the international compliance area. Prior to that, she was a partner with the DC office of Sonnenschein, Nath & Rosenthal. She also spent four years in London and is qualified as a Solicitor to the High Court of England and Wales, practicing in the international arena with the law firms of Theodore Goddard & Co. and Herbert Smith & Co. She also served as an attorney in the Office of the Legal Advisor at the Department of State and was a member of the U.S. delegation to the UN working on the first anti-corruption multilateral treaty initiative.



LRN is the global leader in ethics and compliance solutions. More than 2,500 companies and 30 million learners worldwide utilise LRN services and take LRN courses to help navigate complex regulatory environments and foster ethical and inclusive cultures. Recently, Compliance Learning from Thomson Reuters joined forces with LRN to brings its expertise in financial services and related risk areas to the platform purpose-built for E&C programme management. Visit for more information.