Compliance professionals have come to appreciate the adage that “tone at the top”—the values espoused and acted upon by the senior management team—is critical in shaping an ethical corporate culture. What’s now becoming clearer is that while tone-at-the-top remains important, it alone isn’t sufficient to foster ethical behavior by all employees, especially when they’re scattered across the globe, spanning countries, cultures, and languages. 

Middle managers, including business leaders at the company’s remote locations, play a major role in shaping the culture of the organization and influencing the behavior of their direct reports.“It’s important for managers to be engaged,” says Mary Snyder, senior director of advisory services at GRC solutions provider SAI Global. “They can be a great funnel in both directions of issues and concerns.” Moreover, large compliance failures often start with a small issue. When managers and employees have a way to ask questions and address challenges, issues can be resolved before they escalate, she adds.