It is often said that compliance must exist in an organization from the boardroom to the shop floor. Yet, one of the most important parts in that hierarchy is the middle of an organization. The reason is pretty straightforward, as middle management is the level that employees most often deal with and to whom they look for their clues as to what the organization really expects from them, separate and apart from what the organization as a whole says it expects of them. 

What should the tone in the middle be? That is, what should middle management’s role be in the company’s compliance program? Most employees take their cues from how middle management responds to a situation, meaning the role of middle management is a critical one. Moreover, middle management must listen to the concerns of employees, even if it is unable to directly affect a direct change; it is important that employees have an outlet to express their concerns. 

Organizations should train middle managers to enhance listening skills in the overall context of providing training for their “Manager’s Toolkit.” This can be particularly true if there is a compliance violation or other incident requiring some form of employee discipline. Most employees think it is important that there be “organizational justice,” so that people believe they will be treated fairly. Without organizational justice, employees typically do not understand outcomes; but if there is perceived procedural fairness, an employee is more likely to accept a decision that they may or may not agree with.

Employees often look to their direct supervisor to determine the tone of an organization and what it will be going forward. In fact, most employees of large, multinational companies may never have direct contact with the CEO or even senior management. By moving the values of compliance through an organization into the middle, companies will be much better positioned to inculcate these values and operationalize compliance with them.