One thing is true about the ubiquitous phrase tone at the top; if you want to effect cultural change, it must start with top management. If there is no will to actually make a difference it does not matter how experienced any compliance professional might be; no will at the top and there will be no change throughout an organization. We may be observing this play out at Volkswagen. One might think having just concluded the largest fine ever for fraudulent emissions testing software, VW might have a bit more sensitivity to this fact.
