Even with a great tone-at-the-top and in the middle, you cannot stop. One of the greatest challenges of a compliance practitioner is how to affect the “tone at the bottom.” Employees often look to their direct supervisor to determine what the tone of an organization is and will be going forward. Many employees of a large, multinational organization may never have direct contact with the CEO or even senior management. By moving the values of compliance through an organization into the middle, you will be in a much better position to inculcate these values and operationalizing compliance with them.
One of the things you can do is assemble a compliance focus group to find out how business is done in the field and if it differs from what your company expects from an ethical and compliance perspective. Begin by assembling a group of employees who are familiar with the challenges of doing business in a compliant manner in certain geographic regions to discuss the challenges of doing business ethically and in compliance. Ask them questions about their understanding of your compliance regime. Lead a discussion that attempts to identify any what is different in practice and in theory and then how you can move from theory to practice to operationalizing compliance. Finally, and in the feedback step, test how to more fully operationalize your compliance regime. These tests can be accomplished in the regular course of business or through a special project with a special team and separate budget.
By engaging employees at this level, you can find out not only what the employees think about the company compliance program but use their collective experience to help design a better and more effective compliance program. Employees want to do business in an ethical manner. Given the chance to engage in business the right way, as opposed to cheating; will win the hearts and minds of your employees almost all the time. By using the protocol suggested by the authors you can not only find out the effect of your company’s compliance program on the employees at the bottom, but you can affect them as well.