We always hear about the importance of tone-at-the-top.  Corporate leaders are very familiar with how to say the right things about ethics and compliance and the company’s culture.  But we all know that words are cheap – it is conduct that matters, and it is behavior that ultimately builds trust in an organization.

In large corporations, however, the tone-at-the-top can only go so far.  No matter how effective the leadership is in reinforcing the company’s commitment to ethical behavior, it is essential that middle managers carry the responsibility for promoting ethical behavior.

This is where many companies are failing to follow-up.  Employees want to report misconduct or concerns to their immediate supervisors.  This phenomenon makes sense given human nature – we all want the approval of our supervisors.  Interestingly, very few supervisors are equipped to handle employee concerns, and even fewer are trained on how to promote and reinforce the importance of ethics in its immediate employees.

To promote a culture of ethics, companies have to develop a cascading leadership system where a commitment to ethics and compliance begins at the top, stretches to the middle and extends to all employees.  The critical link in this process is middle managers.

Companies have to devote time and attention to train middle managers on how to instill a culture of ethics in his/her immediate employees.  Working with ethics and compliance staff, middle managers have to learn specific strategies for demonstrating a commitment to culture and promoting a message to reinforce ethical values.  This is a multi-prong strategy that requires middle managers:

• To promote a speak up culture within the employee group;
• To understand how to respond to employee concerns;
• To train and reinforce ethical values with his/her employees; and
• To develop effective communications and listening strategies to underscore the importance of ethical principles in each employee’s day-to-day responsibilities.

In ethical companies, employees often confess they understand the company’s culture but need direction in how the company’s values apply to their day-to-day responsibilities.  A middle manager can define exactly the connection between ethical values and employee responsibilities.  In some respects, middle managers are in the best position to explain the connection between corporate values and employee responsibilities.

Middle managers also need to learn how to listen to employee concerns, respond to such concerns and build trust with his/her employees.  Not everyone is a good listener, and it is important for middle managers to listen, communicate empathy and then develop skills to support the employee.

An ethics and compliance program depends on these critical interactions between middle managers and employees.  While senior leadership conduct and communications are important functions to a company’s culture, ethics and compliance officers have to spend more time cascading culture and leadership principles with middle management.  Specific training programs, ethics teaching materials and other materials should be developed for middle managers.  These materials can be modified as each manager sees fit for his/her specific employee group, but the principles described in these materials can be used for important learning moments.