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. 

Thomas Fox has practiced law for over 40 years. Tom writes the daily award-winning blog, the FCPA Compliance and Ethics blog and founded the Compliance Podcast Network. Tom leads the discussion on AI in...