A panel at the Global Ethics Summit, discussed the topic
of "Tone from the Middle". The panelists were Chad Fentress, AGC for Accenture;
Matthew Pachman, CCO for Altegrity and Maarten Westermann, Senior Director for
Corporate Executive Board. The panel was moderated by Dr. Chris MacDonald
Visiting Scholar at the University of Toronto. The discussion was around the
issue of how does a company "push down" the tone from the top to the middle of
One question presented was "What should the tone in the
middle be?" Pachman emphasized that his key question was "what understanding do
want as a company?" That is, what should middle management's role be in the
company's compliance program? He believes that this role is critical because
the majority of company employees work most directly with middle, rather than
top management. He feels that most employees will take their cues from how
middle management will respond to a situation.
Westermann followed up on this point in the context of a compliance violation
or other incident which requires some form of employee discipline. He believes
that most employees think it important that there be "organizational justice"
so that people believe they will be treated fairly. He further explained that
without organization justice, employees typically do not understand outcomes
but if there is perceived procedural fairness that an employee is more likely
accept a decision that they may not like or disagree with.
Westermann also said that middle management must listen
to the concerns of employees. Even if middle management cannot affect a direct
change, he believes it is important that employees need to have an outlet to
express their concerns. Fentress agreed with this and felt that middle
management should receive training to enhance listening skills in the overall
context of providing training for what he termed the "Manager's Toolkit".
Chad Fentress began the discussion be noting that because
of the 200,000+ employee base of Accenture, the company could not provide live
training by members of the compliance department to each employee. To assist in
the overall training effort the company created compliance champions within
regions. These champions received specialized training and they went out
through the organization to supplement the training put on by the compliance
department. He concluded by noting that an organization should use its core
values as teaching points and if your company's core values do not lend
themselves as teaching points, perhaps they should be revised.
In the area of communication of company values, all
panelists agreed that a company must speak with one voice. This core concept
needs to be communicated throughout the organization. This concept is not meant
as challenge to employee's personal views or their lifestyle but as a company,
it is important to speak as one.
We have previously written extensively regarding "Tone at
the Top". The focus of this panel was that the message must permeate down into
the ranks. Any robust compliance program must have all levels of your company
engaged. The information presented by these panelists should help you in your
company's middle management level.
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© Thomas R. Fox, 2011
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