Compliance Experts Discuss Setting the “Tone in the Middle”

In the realm of ethics and compliance, there is a great deal of emphasis on setting an appropriate “tone from the top.”  However, a lot can be lost in translation as that message reaches – or does not reach – the broader employee population.  One way to assure that that message reaches its intended recipients, and achieves its intended effect, is to have managers set an appropriate “tone in the middle.”  A recent program sponsored by the Society of Corporate Compliance and Ethics explained why setting the tone in the middle can help to achieve ethics and compliance goals and discussed strategies for setting that tone, as well as potential impediments to doing so.  The program featured Michael Levin, Senior Director of Compliance at Freddie Mac; and Kirsten E. Liston, an Associate Vice President of SAI Global Limited.  See also “Measuring the Efficacy of Ethics and Compliance Programs,” The FCPA Report, Vol. 3, No. 12 (Jun. 11, 2014). 

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