Tone at the Top

By Lauren Barnett
Compliance Content Specialist, PharmaCertify

In the world of corporate ethics and compliance there’s a great deal of talk about “tone at the top.” I think most people working in commercial compliance would agree that tone at the top is an essential and foundational component of an ethics and compliance program. Bob Lane, Chairman of John Deere, recently said, “The unmistakable linking of words and deeds in all aspects of business is one of the best ways to assure that the ethical tone is matched with actions.”[1]

Nothing does more to silence the tone at the top than failure to match words and deeds.  The news is littered with tales of what happens when the actions of those at the top do not match their words. In a time when the government has made good on its promise of holding individuals liable for violative behavior in a company, doesn’t the tone at the top need to be continuously reviewed and modified?

Considering that as individuals, we can only truly control our own behavior, those at the top can at least enhance their tone by implementing informal ethics and compliance training through their daily interactions. One effective first step is to take the time to talk with colleagues about one’s own ethical dilemmas, whether the response to those dilemmas proved to be the right decision and what was learned in the process.

Something as simple as a note to the compliance officer that can be shared, or a picture on the company intranet showing timely completion of the required annual compliance training is another informal way to communicate commitment to supporting an ethical culture. By enhancing how they model their commitment to ethical behavior, executive management shows employees that setting the tone at the top isn’t just “corporate speak,” but a viable dedication to changing behavior, as an executive’s direct reports model that same commitment to their own direct reports and throughout the company.

Encouraging this more open and interactive dialogue about ethics and compliance from the top can certainly get the ball rolling in the on-going process of creating a culture in which the “right way” to do business is never in doubt.

1 Lane, Bob (2009). The Role of Tone at the Top.  Retrieved from:

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