Every corporate compliance program has roughly the same parts: a Code of Conduct, training modules, a hotline, some governance structure sitting on top. What separates a program that merely exists from one that actually works isn’t whether those parts are present. It’s what happens inside them.

Ethisphere’s Ethics Quotient® (EQ) measures that difference directly, evaluating how ethics and compliance programs function day to day rather than how well a company describes them on paper. The 2026 class of World’s Most Ethical Companies® Honorees – 138 organizations across 40 industries and 17 countries – offers a working definition of what an effective compliance program actually looks like in practice.

What Makes a Compliance Program Effective

Joe Santosusso, Chief Compliance Officer at eight-time Honoree WD (formerly Western Digital), draws the line clearly. Compliance, especially in heavily regulated areas, can turn into a check-the-box exercise. Ethics is what drives culture. “These awards are not objectives,” he said. “These are outputs of the hard work that we do.”

That distinction runs through every conversation Ethisphere has had with this year’s Honorees. A compliant program follows the rules. An effective one gives employees the tools, and the trust, to make good decisions before a rule ever has to be invoked. Erica Salmon Byrne, Chief Strategy Officer at Ethisphere, has spent two decades watching this play out. The core questions remain constant: are employees equipped to make the right call in their daily work? Do they know where to go for help? Can the organization respond quickly and transparently when something goes wrong? Those questions, she said, “have not changed in the last two decades. Those continue to be the heart of the questions we ask.”

The Throughlines Behind Every Honoree

Three practices show up again and again among organizations that earn this recognition, and none of them require a bigger budget so much as a different orientation toward the work.

Transparency about outcomes. Over the past three years, Ethisphere has tracked a six-percentage-point increase in Honorees sharing investigation statistics, such as case volume and resolution outcomes, with all employees. More than 75% now do this quarterly, semiannually, or annually. Salmon Byrne connects this directly to speak-up behavior: an employee who knows that most substantiated cases end in coaching, not termination, is far more likely to raise a hand.

Manager accountability. For the first time, a majority of Honorees (51%) now require managers to have regular integrity conversations with their teams rather than simply encouraging it. That shift from optional to expected tracks with what Ethisphere’s culture data has shown for years. Managers shape an employee’s willingness to speak up more than any policy does.

Programs built to scale. FedEx manages compliance across more than 500,000 employees in 220 countries and territories. Rather than trying to reach every site through visits, the company is expanding its integrity ambassador program by folding it into safety and culture roles already embedded at the facility level, according to Chief Compliance Officer Pete Blumberg. JLL, an 18-time Honoree, took a similar meet-people-where-they-are approach with data. Instead of training an ethics professional in analytics, the company hired a data specialist and taught them ethics, says Kendall Mills, JLL’s head of ethics and compliance for the Americas. That decision helped JLL move past simple benchmarking figures into deeper questions, including why high training-completion rates in a given country didn’t always line up with strong culture-survey results. It’s a gap worth investigating rather than ignoring.

Download the free 2027 World’s Most Ethical Companies application and see how your program’s practices compare to the ones described above.

What Benchmarking Reveals That Self-Review Can’t

Internal reviews carry a built-in blind spot. The people running them already believe in the program. External evaluation removes that blind spot. Pete Blumberg described it through a litigation lens. You can believe your program is strong, but proving it is a different exercise entirely. “Send us your policy. Send us your guidelines. Send us your alert line stats,” he said, describing what happens when someone actually tests the claim. “When you have to actually document what you are claiming in a very thorough way, that’s when the rubber meets the road.”

Santosuosso calls benchmarking “the greatest tool that anybody in compliance has,” because no program is ever finished. Regulatory expectations and enforcement priorities keep moving, and a program that stands still falls behind. Noreen Fiero, chief ethics and compliance officer at 15-time Honoree Principal Financial Group, has found that consistent, recurring measurement, rather than a new survey every year, is what lets a team track real trends and operate as a trusted strategic adviser instead of a once-a-year compliance exercise.

FedEx didn’t win World’s Most Ethical Companies recognition on its first application. What the company got instead was detailed feedback on exactly where the program fell short, feedback it used to close those gaps over the cycles that followed. That’s what internal review can’t give you. A map of where the gaps actually are, drawn by someone with no reason to be generous.

What the Ethics Quotient Actually Tests

The EQ evaluates five categories: Culture of Ethics, Corporate Governance, Ethics & Compliance, Third-Party Management, and Environmental & Social Impact. Applicants answer more than 240 questions and submit documentation, such as governance policies, training records, and audit results, to support every answer. Ethisphere’s analysts review that evidence and benchmark it against peer organizations.

That structure exists to test compliance program effectiveness across an entire organization, not how well one department can describe its work. Every applicant, recognized or not, receives a scorecard showing exactly where they stand against that year’s Honorees, along with documentation feedback they can act on right away.

See Where Your Program Stands

Early access to the 2027 EQ questionnaire opened on June 24, and the application portal opens on July 29, 2026, with submissions due October 29, 2026. If your program already has the fundamentals in place, a code, training, governance, a hotline, this is how you find out whether those fundamentals are excellent or merely present.

Download the free 2027 World’s Most Ethical Companies application and benchmark your program against the organizations that define what corporate compliance excellence actually looks like.

Author Bio

Bill Coffin  |  Editor-in-Chief, Ethisphere Magazine, Ethisphere

Bill Coffin is the Editor-in-Chief of Ethisphere Magazine and supports the larger content strategy of Ethisphere. He is an internationally recognized writer and editorial leader in the fields of ethics, compliance, insurance and risk management. His work has appeared in The Wall Street Journal, BusinessWeek, Forbes and Fortune, as well as Compliance Week, National Underwriter, Risk Management, Best’s Review and other B2B media. Previously, Bill served as Director, Senior Editor at AIG, leading content strategy for one of the world’s largest insurance companies.