By Adam Turteltaub

If all you’re worrying about is tone at the top, you’re missing a key portion of the choir.  With most people reporting to middle managers, they play in integral role in ensuring a culture of compliance and ethics truly permeates the organization.

Evie Wentink, Senior Compliance Consultant at Ethical Edge Experts observes that while many organizations invest in crafting comprehensive codes of conduct and articulate expectations for ethical leadership, they often fall short in equipping managers with the tools, training, and support necessary to fulfill those expectations. This gap can undermine the effectiveness of compliance efforts and leave companies vulnerable to ethical lapses.

At the heart of the issue is a lack of intentional communication. Middle managers are frequently expected to embody and promote ethical leadership, yet they are rarely given a clear understanding of what that entails. To bridge this gap, organizations must develop structured plans that define ethical leadership in practical terms. These plans should include specific deliverables, resources, and expectations tailored to the manager’s role. By doing so, companies can ensure that managers are not only aware of their responsibilities but also empowered to carry them out effectively.

Authentic, ongoing conversations led by these managers are a cornerstone of a successful compliance culture. These discussions should not be limited to formal training sessions or annual reviews. Instead, they must be woven into the fabric of everyday operations. Managers should be encouraged—and required—to initiate “ethics or integrity minutes” at the start of team meetings. These brief segments provide a consistent opportunity to address ethical topics, reinforce values, and normalize open dialogue about compliance issues.

To support these conversations, organizations should provide managers with practical tools. These might include:

Ethics spotlight cards that highlight key compliance themes.

News articles that can be used to spark discussion around real-world ethical dilemmas.

Access to updated policies and codes of conduct, with notifications when changes occur.

Tracking and analyzing these conversations is equally important. Compliance teams should maintain records of who is engaging in discussions, what topics are being covered, and which issues are generating the most questions. This data can be invaluable in identifying risk areas, refining training programs, and tailoring future communications. Often, the most common questions arise immediately after a training session, indicating that such moments are prime opportunities for deeper engagement.

Moreover, it’s essential to recognize the broader impact of middle management on organizational integrity. Prosecutors and regulators increasingly view middle managers as pivotal figures in corporate misconduct cases. Their actions—or inactions—can significantly influence whether a company succeeds or fails in maintaining ethical standards. Consequently, fostering a culture of accountability and proactive communication at this level is not just beneficial—it’s critical.

Ultimately, the goal is to create an environment where ethical conversations are natural, frequent, and valued. When managers consistently lead by example and facilitate open dialogue, employees become more comfortable raising concerns and asking questions. This cultural shift enhances transparency, reduces risk, and strengthens the overall integrity of the organization.

In summary, bridging the compliance gap at the middle management level requires a multifaceted approach: clear expectations, practical tools, authentic conversations, and ongoing tracking. By investing in these areas, organizations can transform their compliance programs from static documents into dynamic, living systems that truly support ethical behavior at every level from the top on down.