Planes, trains and automobiles can be three of the most important leadership tools for any compliance professional. For it is through these transportation methods that you get out of the office and into the field to meet and talk with your stakeholders, both internal and external. This greatly facilitates a 360-degree use of communication. 360-degrees of communication considers not just that classic form of communication one person to another but rather the concept of every interaction as a form of communication. If you are out of your office, your internal and external stakeholder will see not only what you are communicating but how you are communicating. It is in these interactions, you are literally always communicating. It may be that you are communicating to a group across group boundaries to the constituencies which you had not even planned to communicate to or with. This means that a 360-degree approach to communication is much more holistic approach to communication.

When you tie a 360-degree approach to ethical leadership you have a power tool to create a successful compliance program. But it is more than your commitment as a CCO or compliance practitioner. Senior management must not only be committed to doing business in compliance with these laws but they must communicate these commitments down to the organization. But leadership is not limited to only to senior management within an organization. Tone at the Top begets Tone in the Middle; which begets Tone at the Bottom. At each rung, there is the need for 360-degrees of compliance communications. In “Leadership is a Conversation”, authors Boris Groysberg and Michael Slind discuss how to improve employee engagement in today’s “flatter, more networked organizations.”

It is the how leaders handle communications within their organizations that is as important as the message itself. The process should be more dynamic and more nuanced and should be conversational. It is a model of leadership which uses “organizational conversation” resembling ordinary person-to-person conversations. This model has several advantages, including that it allows a large company to function like a small one and it can enable leaders to “retain or recapture some of the qualities…that enable start-ups to out-perform better established rivals.” There are four elements of organizational conversation: intimacy, interactivity, inclusion and intentionality.  

Intimacy: Getting Close

You should focus on two skills: listening and authenticity, because physical proximity may not always be feasible but emotional or mental proximity is required. As a corporate leader, a CCO should “step down from their corporate perches and then step up to the challenge of communicating personally and transparently with their people.” This technique shifts the focus of change from a top-down hierarchical model to a “bottom-up exchange of ideas.” 

Interactivity: Promoting Dialogue

Interactivity should make a conversation open and more fluid. You can obtain this by talking with and not just talking to an employee. The purpose of interactivity builds upon the first prong of intimacy. The efforts to close the gap between employees will founder if both tools are not in place along with institutional support that gives employees the freedom and courage to speak up. Here social media can be a useful tool to help foster such interactivity, but take care not to simply use social media as another megaphone. It is more than just social media, it requires social thinking. 

Inclusion: Expanding Employees Roles

Following on from intimacy is inclusion as intimacy should force a leader to get closer to employees while inclusion challenges the employee to play a greater role in the communication process. Inclusion expands on interactivity by enabling employees to put forward their ideas rather than simply batting the ideas to others who might be a part of the conversation. This brings employee engagement into the 360-degree process by calling on employees to generate the content that validates a company’s value. Employees who become committed to a message can become the best brand ambassadors that a company can ever hope to have on its payroll. 

Intentionality: Pursuing an Agenda

While the first three prongs of this model focus on opening the flow of communication, intentionality is designed to bring a measure of closure to the process. The goal here is to have voices merge into a single vision of what the company’s communication stands for. In other words, the conversation should reflect a “shared agenda that aligns with the company’s strategic objectives” that will allow employees to “derive a strategically relevant action from the push and pull of discussion and debate.” The role here for leaders is to “generate consent rather than commanding assent” for a strategic objective. This enables employees at the top, middle and bottom to gain a 30,000-foot view of where their company stands on any issue which has gone through the process.

The 360-degree approach requires you to be cognizant of how communications works wherever you are and in whatever medium you are communicating. It also focuses on the cultural differences that exist across borders, recognizing that cultural differences sometimes they exist within the same office or across a team. It is having as much awareness as possible of the audience you are communicating to so that you ensure the messages that you are trying to get through and the information you are trying to gain from that audience is gained in the most effective way possible. You need to be comfortable changing the way you approach different people with different cultures.

Three Key Takeaways

  1. Planes, trains and automobiles.
  2. Use a 360-degree approach to open the flow of communications.
  3. A 360-degree approach allows all company stakeholders to get the big picture.


This month’s podcast series is sponsored by Dun & Bradstreet.  Dun & Bradstreet’s compliance solutions provide comprehensive due diligence reporting and analysis to reduce your risk of working with fraudulent companies by accessing a company’s beneficial ownership, reputation risk and more.  For more information, go to