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

Tone at the top has been a compliance talking point for years, but as compliance programs mature, tone at the top is no longer enough.  “A tone at the top approach alone is not likely to reach as effectively the groups of employees who make real decisions that are going to affect the business,” Jennifer Newstead, a partner at Davis Polk & Wardwell, told The FCPA Report.  To effectively spread the compliance message, companies must also focus on tone in the middle.  This multi-part series will assist companies in evaluating their current culture and enhancing their tone in the middle to strengthen their compliance program.  This, the first article in the series, will discuss who the “middle” actually is, why tone in the middle matters and the challenges of creating a compliant tone.  Future articles will specify: how a company should prepare middle managers to spread the compliance message, actions that middle managers can take to emphasize compliance, and strategies for monitoring tone.  See also “Five Tools Every Chief Compliance Officer Needs for Effective FCPA Compliance: Title, Authority, Access, Budget and Culture (Part Two of Two),” The FCPA Report, Vol. 2, No. 8 (Apr. 17, 2013) (discussing tone at the top).

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