Academic research into codes of ethics has given us valuable information on the subject but has failed to provide an all-encompassing understanding of the contents of actual codes. This paper looks at what is presently known about this subject, presents a conceptual model that integrates the different elements that go into a code of ethics, describes the dynamics that explains why each company's code of ethics has a distinct content, and presents preliminary results obtained after having analyzed a cross-section of the code of ethics of member companies of the Ethics and Compliance Officer Association.