A few decades ago, Japanese car manufacturers embraced the philosophy of continuous improvement. They looked at every car part and assembly process, and tried, every day, to make it a little better.
The same philosophy can be applied to building an ethics and compliance program or a corporate culture. Look at every program element and corporate process and try, every day, to make them a little better.
If you do anything today the same way you did it yesterday, you are not improving. If you are not improving, you are falling behind (your competition) because the world is changing.
The key to continuous improvement is continuous feedback. Build feedback in everything that you do (code of conduct, policies, training, communications, controls, audits, investigations, etc.). Listen, learn, improve.