Everyone knows the mantra – yes, we need tone at the top, but we also need tone in the middle and tone at the bottom.

Every aspect of this statement, however, requires more work than everyone thinks. Tone at the top is not established by having the CEO create a video message, write a letter and/or communicate the company’s commitment to ethics and compliance. It is not a one step process.

Tone at the top requires continuous commitment. Tone comes from repetitive but effective messaging and conduct. Managers and employees want to know what the company’s tone is and they want to know how senior management acts to promote and ensure a culture of integrity.

Tone in the middle is a distinct issue. It requires a partnership between leadership messages and values and managerial communication and conduct. More companies recognize that middle management needs the training and the tools to carry out a tone in the middle.

Managers want to promote an ethical culture. It makes their jobs easier. They want employees to speak up. Middle managers, however, need support from senior management to carry out these functions.

Compliance professionals need to provide middle managers with a toolkit to carry out this job. The toolkit should include talking points on responding to employee concerns; messages to email to employees, scripts of messages to deliver at staff meetings, and suggested best practices for following up on issues and addressing employee concerns.

A company’s tone requires regular communications throughout the organization. Managers and employees want to hear from the C-Suite. Senior executives have to cascade the message and hand-off the responsibilities. Middle managers have to be ready to carry out this function.

On the front lines, employees need to hear a consistent message from senior and middle management – we live and work by our code, we follow our values and we report misconduct when we learn about it. This message has to be reinforced often and by managers on the front line or in the trenches.

All of these ideas – from the top to the bottom – sound great in theory. Companies need to be more vigilant when it comes to training, communications and the last and important piece – monitoring the company’s culture.

A company’s culture cannot be measured once every year by employee surveys. A targeted and more comprehensive approach is needed to answer a fundamental question – is the company’s message permeating the organization?

A proactive approach to measuring culture is needed. A company should conduct targeted surveys, focus groups and interviews in high-risk operations. The results should be reported to the board and to senior management. If the inquiry confirms the message is getting through, then the company can move on to plan new initiatives and monitoring activities.

On the other hand, if the message in a high-risk operation is not getting through, the company has to take affirmative steps to enhance its messaging. There are a number of explanations for why this can occur – it can be a mix of the message and the audience.

Culture surveys can also focus on distinct categories of managers and employees – high-risk operations can be frontline employees throughout the organization or in a specific market. It is important to focus efforts and attention on categories of operations and employees so that monitoring activities can be allocated to high-risk activities.