31DaystoMoreEffectiveCompliancePrograms: Day 4 - Moving Compliance Tone Down Through an Organization

Mike Volkov has said, “Even when a company does all the right things at the senior management level, the real issue is whether or not that culture has embedded itself in middle and lower management. A company’s culture is reflected in the values and beliefs that exist throughout the company.” To fully operationalize your compliance program, you must articulate the message of ethical values and doing business in compliance and then drive that message from the top-down throughout your organization.

What should the tone in the middle be? What should middle management’s role be in the company’s compliance program? This role is critical because the majority of company employees work most directly with middle rather than top management, and, consequently, they will take their cues from how middle management responds to a situation. Perhaps most importantly, middle management must listen to the concerns of employees. Even if middle management cannot affect a direct change, it is important that employees have an outlet to express their concerns. Your organization should train middle managers to enhance listening skills in the overall context of providing training for their “Manager’s Toolkit.” This can be true if there is a compliance violation or other incident requiring employee discipline. Most employees think it is important that organizational justice so that people believe they will be treated fairly. For if there is organizational justice, it engenders perceived procedural fairness, making it more likely an employee will be willing to accept a decision that they may not like or disagree with the result.

Three key takeaways:

1. Tone at the top—direct supervisors become the most important influence on people in the company
2. Give your middle managers a Tool Kit around compliance so they can fully operationalize compliance
3. Organizational justice is an additional way to help operationalize compliance
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