Without effective mechanisms for implementation, a code of ethics would not impact employees’ behavior. This study aims to inductively investigate implementing a code of ethics to improve the current understanding of this subject and make implementing a code of ethics in organizations more effective. To this end, the Grounded Theory (GT) approach is used. The research sample comprises managers and employees from 12 ICT companies in the Tehran Stock Exchange. Data were collected by conducting interviews and using the theoretical sampling method. On this basis, 23 HR managers/experts were interviewed. The collected data were analyzed using the approach proposed by Strauss and Corbin (1998). The findings indicate that organizations are driven to implement a code of ethics due to two main reasons: external pressure and internal needs. In implementing a code of ethics, they face challenges such as low top management support, improper financial situation, and unsupportive employee perceptions and attitudes. To implement a code of ethics, surveyed organizations take initiatives such as code of ethics definition and redefinition, communication, code of ethics training, punishing violations, and awarding obligations and social methods. Such initiatives can improve an organization’s ethical climate and create a distinguished identity, whereas they can yield undesired consequences if proven unsuccessful.
