Global compliance programs often feature codes of conduct, policies, training, hotlines, investigations, and risk assessments. While these “seven elements” are essential, they do not guarantee an effective Ethics and Compliance (E&C) Program. Success depends on company culture and, critically, the involvement of mid-level managers whose engagement determines if these systems work in practice.
Recent observations from a multi-session Integrity Playbook, Ethical Leadership training pilot with managers in legal, IT, supply chain, communications, and operations at Azercell Telecom, the largest mobile telecom provider in Azerbaijan, reinforced a truth many compliance professionals recognize. This brings us to a core insight:
Compliance fails not because of missing policies, but when managers are unprepared to act under pressure.
As the Integrity Playbook pilot began, it became clear that many managers expected a typical leadership course. However, what they encountered was quite different—and for some, challenging.
The focus was not on slogans or aspirational values. Instead, it addressed:
- How decisions are made when timelines are tight
- What happens when personal relationships conflict with business duties
- When to escalate, when to pause, and when to ask for help
- How accountability actually shows up when mistakes occur
In early discussions before the Integrity Playbook pilot, compliance was often seen as “someone else’s job,” typically assigned to legal, compliance, risk, or headquarters. This longstanding perception shaped initial attitudes.
Every time someone asks, “What do you do?” We reply: “I work in compliance.” Oftentimes, I am met with responses like, “Oh…like HR?”, “Like auditing?”, “Like legal?” or the classic, “What is that exactly?” It is a fair question.
The compliance function is often not visible, yet it is required everywhere in the organization. This lack of visibility has to change, as do misperceptions around its purpose.
Compliance isn’t there to slow business down or add cost to the company’s budget; it should be a strategic partner to the business. Leaders and the entire organization need to see it as a strategic partner to help navigate the world of increasing regulations, digital transformation, and global operations.
With this in mind, the next time someone asks, “What is compliance?” I’ll proudly respond that compliance is about making decisions by considering rules, values, and real-world consequences. It also means expecting managers to do this every day. When compliance works this way, it becomes part of daily decisions, not just a policy. Tone in the middle is not just a concept; it is the foundation of a strong compliance culture. Strong compliance begins with setting an example, not enforcement.
We did something new, seeing this reality of compliance as “someone else’s job.” With the help of Ethical Edge Expert’s innovative program, the Integrity Playbook, and Ethical Leadership training, Azercell Telecom created a custom program for our section managers. The goal was to deepen their understanding of the compliance program, function, and their responsibilities as ethical leaders through interactive lessons.
The Integrity Playbook Ethical leadership training pilot consisted of three separate hour-and-a-half-long sessions, conducted for two groups of managers. By the third session, we observed a shift in how the managers framed their thinking.
Managers began to recognize that handling issues early—through conversation, judgment, and escalation—prevents them [compliance issues] from becoming legal or regulatory crises later.
Compliance stopped feeling like a distant function and became part of their role as leaders.
At the same time, many compliance professionals, including myself, often grapple with a recurring question: “Where should I draw the line between constructive questioning and overstepping in exploration of ethical dilemmas?”
Think of it as muscle training. As leaders, we build the habit of selecting one compliance risk case each week and working through it in depth, which helps us build our E&C muscle in daily practice.
The compliance team, leadership team, managers, and all employees must continue to pursue excellence in Integrity regardless of real-world pressures. This means staying diligent in our responsibilities and upholding the business’s values, mission, and code of conduct as a leader. This is what the Integrity Playbook and Ethical Management training provide: It teaches managers and all leaders how to be Ethical Leaders.
Ethical Blindness
Compliance can absolutely fail when good people become ethically blind, which happens frequently because compliance programs are viewed as a passive role rather than embedded in daily activities across the organization. Even the best rules, policies, and systems can’t prevent misconduct if the people expected to follow them don’t practice them daily. Ethical blindness happens subtly: people may rationalize small compromises, follow group norms without questioning them, or prioritize results over integrity, often without realizing it.
This isn’t just about enforcing rules; it’s about helping people stay aware, reflective, and morally alert by incorporating ethical leadership training at all levels. That’s why practices like ethical “muscle training,” real-case walk-throughs, and continuous discussion about integrity are so important—they keep ethical awareness active, so good people don’t unintentionally drift into blind spots.
After reading the book Dark Pattern, we can see that the authors were drawing on the latest insights from behavioral science. The authors identified nine toxic elements that can quietly erode ethics in an organization and ultimately lead to corporate scandals. This book also provides nine actionable lessons that help organizations build moral resilience, along with practical ways to strengthen ethical awareness, decision-making, and accountability, so that good people don’t become ethically blind.
Accountability Gap
Another critical area of misalignment is the perception of consistency in enforcing ethical standards, particularly between senior and middle management. This discrepancy points to an accountability gap, in which enforcement mechanisms may be inadequately implemented or unevenly applied.
The 2025 Ethics & Compliance Program Effectiveness Report – Caught in the Middle showed that contributing factors to this accountability gap include (i) perceived favoritism or uneven disciplinary measures; (ii) lack of transparency in decision-making processes related to compliance violations; (iii) limited involvement of frontline employees in feedback loops to evaluate the effectiveness of compliance enforcement.
Fostering a shared understanding of ethical standards and ensuring accountability requires transparency and fairness across all levels of the organization – top-middle-bottom lines. Under the enhanced communication efforts, regular town halls, anonymous feedback systems, and accessible reporting mechanisms are used to ensure frontline employees feel heard. On the other hand, integrity moments meetings with frontline employees by leaders will lead to trust and gain insights into operational challenges. The last one is to establish tailored E&C programs that emphasize the importance of enforcement and each employee’s role in upholding ethical standards. Employee lived experience with leadership perception together should lead to a strong compliance program.
To return to a central point: Policies, codes, and training frameworks are necessary, but they are not what determines whether a compliance program works in practice.
The real test happens in the everyday decisions managers make — when deadlines are tight, pressure is high, and judgment matters more than procedure.
Organizations that invest in developing ethical decision-making at the managerial level strengthen the bridge between policy and practice. They move compliance out of the handbook and into the daily rhythm of leadership.
Because ultimately, a strong compliance culture is not built through enforcement alone. “Inconsistent enforcement environments make principled ethics more important — not less. Be clear about principles and values,” as noted in an article by Hui Chen, “Four Ways 2026 Will Shift Corporate Compliance and Ethics.”
In conclusion, a Culture of Integrity thrives when managers consistently make the right choices. The pilot’s key lesson is this: Ethics and compliance must be ongoing, woven into daily actions—not a one-time event. Only then does compliance become a strategic asset, not merely a cost center.
Mrs. Sevinj Novruzova is a legal, ethics, and compliance professional with over 15 years of experience, serving as Head of Ethics and Compliance at Azercell Telecom LLC. She holds a PhD in Commercial Law, is an Affiliate of NYU Law School Information Law Institute, and focuses on AI ethics and compliance governance.
Evie Wentink is a CCEP-I-certified compliance executive with 15+ years building ethics-first cultures — now advising boards and leadership through Ethical Edge Experts LLC.
