Via LinkedIn, I got the following comment on my Tone at the Top post, below (until I get permission from the person who wrote the comment, I won’t post his name.):
Howard, I have to say that I agree with your comments. The one thing I think should also be considered is that middle management must have bonus or compensation dependant targets that drive them to achieve or reward them for compliance rather than it being a sidebar to their key compensation drivers of sales targets.
If the tone from the top ( I hate that term because it only implies messaging not actual activity) hits a middle manager whose performance targets are driven by deals or sales or units produced will they listen to the tone or see it as extraneous? If they have to achieve 80% or more on compliance audits before performance rewards kick in it is a far stronger message.
keep up the good work
Great point, and one which I often make, but overlooked here, obviously.
Part of an effective compliance program, and one which also implicates tone from the top, is how sales people are compensated. In 99.999%, the answer is “according to how much they sell.” One of the important training pieces is being consistent in your messaging. That means you can’t tell people: it’s okay if you lose business if you refuse a bribe, and at the same time, tell people that they’ll only get paid if they make the sale.
It’s a great point, and one worth remembering.
UPDATE: I spoke with the commenter, and he gave his blessing. If you want to check out an interesting and insightful person, go here to David Harley’s LinkedIn page. He’s at PriceWaterhouseCoopers.