How to Build a Compliant Culture and Stronger Company from the “Middle” (Part Three of Three)

During the last decade, conversations about a company’s compliance messaging have shifted from a focus on tone at the top to a more holistic approach emphasizing tone at every level of the company.  Today, tone in the middle is a crucial element of effective compliance communications, Jennifer Newstead, a partner at Davis Polk & Wardwell, told The FCPA Report.  This article, the third in a series, details ten actions middle managers can take to spread the compliance gospel and provides strategies for monitoring tone.  The first article discussed who the “middle” actually is, why tone in the middle matters and the challenges of creating a compliant tone.  The second article outlined eight steps companies that are implementing or revamping compliance programs can take to support middle-level compliance messaging.

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