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Tone in the middle of an organization

Tom Fox | January 28, 2018

The Evaluation of Corporate Compliance Programs makes clear that a company must have more than simply a good “Tone-at-the-Top”; it must move down through the organization from senior management to middle management and into its lower ranks. This means that one of the task is to get middle management to respect the stated ethics and values of a company, because if they do so, this will be communicated down through the organization.

A company’s culture is reflected in the values and beliefs that exist throughout the company. To fully operationalize your compliance program, you must find a way to articulate and then drive the message of ethical values and doing business in compliance with such anti-corruption laws such as the FCPA from the top down, throughout your organization.

What should the tone in the middle be? What should middle management’s role be in the company’s compliance program? This role is critical because the majority of company employees work most...

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