There are many levels in every company. They are usually broken down into senior management or the top, middle management and the front lines where business is actually down, and the lower level. Each level has its own compliance challenges. 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 of a client who described his role at the company as “the ambassador for compliance.” I can think of no better description for 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.

Tone 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.

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