Last summer I ran a two-week, combined blog and podcast series on the Ten Hallmarks of an Effective Compliance Program. The series was quite well received. As I fancy myself the Nuts and Bolts compliance guy and inspired an Aussie blogging and podcasting maven named Darren Rowse and his 31 days to a better blog series, this month I am running a 30-day program on how to create and implement a better compliance program. My plan is to run similar series during 2017 where I focus on one issue which the Chief Compliance Officer (CCO) or compliance practitioner can use immediately going forward.

Each day this month, I will present one issue which you can incorporate into your compliance program. The podcasts will be shorter than my normal podcasts, coming in (usually) at 10-15 minutes. I will present a short written text for you and three key takeaways which you can utilize to help create a better compliance program. At the end of the 30 days, you will have a wealth of information which you can use to create not only a better compliance program but a more effective compliance program as well.

The podcasts will be available here, on YouTube, my Libsyn podcast site and on iTunes. Do not worry, I will continue to maintain my other podcasts as well but I wanted start 2017 providing something that no other person or company is providing to the compliance community, short solid tips which you can use to make your compliance program more effective, more efficient and better run.

To give you a taste of what each day in January will look like, I have placed below the text which accompanies today’s post entitled Tones in an Organization.

Welcome to Day 1 of 30 days to a better compliance program. Together with a podcast each day, I will be giving you tip to help you create a best practices compliance program in 2017. At the end of January, you will not only have a good summary of the basics of a best practices compliance program but information that you can incorporate into your compliance regime. Today I consider the various Tones in an organization. Any compliance program starts at the top and flows down throughout the company, which sets the proper character for each level of your organization.

At The Top 

Tone at the Top has become a phrase inculcated in the compliance world. The reason it is so important to any compliance program is because it does actually matter. So how can a company overcome employee attitudes and set, or re-set, its “Tone at the Top”? I once had a Chief Executive Officer (CEO) of a client who described his role at the company as “the ambassador for compliance” and I can think of no better description of the role of a CEO for a best practices compliance program.

In the Middle 

A company must have more than simply a good ‘Tone at the Top’; it must move it down through the organization from senior management to middle management and into its lower ranks. This means that one of the tasks of any company, including its compliance organization, is to get middle management to respect the stated ethics and values of a company, because if they do so, this will be communicated down through the organization.

Tone at the Bottom 

Even with a great ‘Tone at the Top’ and in the middle, you cannot stop. One of the greatest challenges for a compliance practitioner is how to affect the ‘tone at the bottom’. To do so, you must work to engage those at the front lines, including training, communication and the tools to accomplish these tasks. A key question is how to tap into this belief system? The answer is to engage employees in a manner which allows you to not only find out what the employees think about the company compliance program but use their collective experience to help design a better and more effective compliance program.

Three Key Takeaways

  1. What is your tone at the top?
  2. What is your tone in the middle?
  3. What is your tone at the bottom?

For more information on how to set, maintain and evaluate the different tones in an organization, check out my book Anti-Bribery Leadership, co-authored with Jon Rydberg, which is available through by clicking here.


This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business, legal advice, or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified legal advisor. The author, his affiliates, and related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication. The Author gives his permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at

© Thomas R. Fox, 2017