How to Define “Tone-at-the-Top”

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3 Responses

  1. Jose Tabuena says:

    Michael – All good. I would just add that “Tone at the Top” is one of the core principles of the Control Environment under the Committee of Sponsoring Organizations of the Treadway Commission (COSO) framework. A core attribute external and internal auditors are to examine as part of the Control Environment is whether (and the degree) an organization demonstrates a committment to integrity and ethical values.
    So while auditors tend to use Tone at the Top while compliance professional more so refer to the “promotion of culture that encourages ethical conduct and commitment to compliance with the law” as stated under the Federal Sentencing Guidelines. To me they are the same but you want to make sure your auditors and compliance professionals are evaluating this component in a consistent manner.

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