The objective of this paper is to examine the ‘Code of Ethics Quality’ (CEQ) in the largest companies of Australia, Canada and the United States. For this purpose, a proposed CEQ construct has been applied. It appears from the empirical findings that while Australia, Canada and the United States are extremely similar in their economic and social development, there may well be distinct cultural mores and issues that are forming their business ethics practices. A research implication derived from the performed research is that the construct provides a selection of observable and measurable elements in the context of CEQ. The construct of CEQ consists of nine measures divided into two dimensions (i.e. staff support and regulation). They should not be seen as a complete list. On the contrary, it is encouraged that others propose and elaborate revisions and extensions. A practical implication of this paper is a structure of what and how to examine the CEQ in a managerial setting. It may assist companies in their efforts to establish, maintain and improve their ethical culture, norms and beliefs within the organization and supporting them in their ethical business practices with different stakeholders in the marketplace and society. The dimensions and measures of the construct may be used as a frame of reference for further research. They may be useful and applicable across contexts and over time using similar samples when it comes to large companies, as small- or medium-sized ones may not have considered all areas nor have the elements in place. This is a research limitation, but it provides an opportunity for further research.