Seems like some sort of fallacy. If an organization doesn’t have an ethics code, then critics can say that the organization needs to hold themselves up to ethic

Seems like some sort of fallacy. If an organization doesn’t have an ethics code, then critics can say that the organization needs to hold themselves up to ethical standards, if they do have an ethics code, critics can point out, like you have, that there must be a bunch of ethical violations which created the need for the code.