The corporate scandals of 2001-2003 are presumably behind us, but their aftermath lives on. Shareholders’ perception of American business is at an all-time low, as businesses scurry to decipher and satisfy a myriad of complex new regulatory requirements, many engendered by Sarbanes-Oxley. In that context, one hears a lot these days about the ‘tone at the top’—that is, the message a company’s leaders communicate about how their company and its employees should comport themselves. As with any difficult concept, there are many euphemisms employed to describe the same thing. Aristotle called it ‘ethos,’ the sense of credibility or trustworthiness in one’s rhetoric. More recently, the Federal Sentencing Guidelines described the concept as “an organizational culture that encourages ethical conduct and a commitment to compliance with the law.”
