We often hear the compliance refrain on the importance of tone-at-the-top – meaning when the board, the CEO and senior executives demonstrate by communications and by conduct their commitment to a culture of ethics and compliance. This single idea carries with it enormous importance to the success or failure of a compliance program. A positive tone-at-the-top permeates every aspect of a compliance program and specifically...
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...
The phrase tone at the top is becoming trite. Compliance professionals use it over and over, and few people explain how to apply the concept. Speakers and webinar presenters always gloss over tone at the top, emphasizing its importance but providing little practical advice. In some sense, it is hard to define in specific actions since the context and the actors can vary with respect...
We all tend to gloss over a critical requirement for an effective ethics and compliance program – tone-at-the-top. I hate to be dogmatic about the issue but, as Mel Brooks said in the Curb Your Enthusiasm (Season 4, Episode 1), “You either got it or you ain’t.” The same is true for the board, CEO and senior executive commitment to ethics and compliance. Every Chief...
Lauren Connell, Managing Associate at The Volkov Law Group, joins us again for a posting on the Wells Fargo scandal. Lauren can be reached at [email protected]. Wells Fargo’s cultural tone is not easily segregated between “top,” “middle” and “bottom.” Despite the recent cross-selling scandal, in which the CFPB led an enforcement action whose fines total a whopping $185 million, Wells Fargo’s CEO John Stumpf reluctantly...
Compliance professionals are familiar with the phrase “tone at the top,” but what exactly does it mean? Unlike other compliance program components, it cannot be easily formalized and implemented in a policy or procedure. Yet tone at the top is critical to building a culture of compliance – employees and managers do not live in a vacuum, they will reflect the importance of ethical business...
Everyone likes to give advice on the importance of tone-at-the-top. Like many things in life, it is easy to talk about but much more difficult to implement. There are lots of ways to describe or analyze the same issue. In the end the result has to be reached. To boil it down, tone-at-the-top requires leadership. That is pretty obvious. But, what kind of leadership? This...
