The objective of this study is to test the embeddedness of codes of ethics (ECE) in organizations on aggregated data from three countries, namely Australia, Canada and the United States. The properties of four constructs of ECE are described and tested, including surveillance/training, internal communication, external communication and guidance. The data analysis shows that the model has satisfactory fit, validity and reliability. Furthermore, the results are fairly consistent when tested on each of the three samples (i.e. cross-national validation). This cross-national study makes a contribution beyond previous descriptive or exploratory studies by using confirmatory factor analysis and structural equation modeling. Nevertheless, a number of limitations are raised, all of which provide opportunities for further research in refining, extending and testing the proposed ECE model in other cultural and corporate settings. © 2011 Blackwell Publishing Ltd.