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

Effective compliance initiatives must move beyond the board and C-suite and infiltrate the entire organization.  The key to that infiltration is reaching middle managers who are on the ground with employees.  Fostering a compliant tone in the middle, however, requires coordinated efforts by company leadership and the compliance department.  The FCPA Report’s multi-part series is designed to help companies assess their current culture and strengthen their tone in the middle.  This article, the second in the series, details eight steps companies that are implementing or revamping compliance programs can take to support middle-level compliance messaging.  The first article discussed who the “middle” actually is, why tone in the middle matters and the challenges of creating a compliant tone.  The third article will address actions that middle managers can take to emphasize compliance and strategies for monitoring tone.  See also “Customizing Codes of Conduct to Spread the Message of Compliance,” The FCPA Report, Vol. 4, No. 5 (Mar. 4, 2015).

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