Welcome to Day 1 of 30 days to a better compliance program. Together with a podcast each day, I will be giving you tip to help you create a best practices compliance program in 2017. At the end of January, you will not only have a good summary of the basics of a best practices compliance program but information that you can incorporate into your compliance regime. Today I consider the various Tones in an organization. Any compliance program starts at the top and flows down throughout the company, which set the proper character for each level of your organization.

 At The Top 

Tone at the Top has become a phrase inculcated in the compliance world. The reason it is so important to any compliance program is because it does actually matter. So how can a company overcome these employee attitudes and set, or re-set, its “Tone at the Top”? I once had a Chief Executive Officer (CEO) of a client who described his role at the company as “the ambassador for compliance.” I can think of no better description of the role of a CEO for a best practices compliance program.

 In the Middle 

A company must have more than simply a good ‘Tone-at-the-Top’; it must move it down through the organization from senior management to middle management and into its lower ranks. This means that one of the tasks of any company, including its compliance organization, is to get middle management to respect the stated ethics and values of a company, because if they do so, this will be communicated down through the organization.

At the Bottom 

Even with a great ‘Tone-at-the-Top’ and in the middle, you cannot stop. One of the greatest challenges for a compliance practitioner is how to affect the ‘tone at the bottom’. To do so, you must work to engage those at the front lines, including training, communication and the tools to accomplish these tasks. A key question is how to tap into this belief system? The answer is to engage employees in a manner which allows you to not only find out what the employees think about the company compliance program but use their collective experience to help design a better and more effective compliance program. 

Three Key Takeaways

 

1. What is your tone at the top?
2. What is your tone in the middle?
3. What is your tone at the bottom?

For more information, check out my book Anti-Bribery Leadership, which is available through Amazon.com by clicking here.

Learn more about your ad choices. Visit megaphone.fm/adchoices