Day 4 of 31 Days to a More Effective Compliance Program – Moving Compliance Tone Down Through an Organization

In Day 4 of his podcast series on creating more effective compliance programs, Tom Fox says that middle management is the key to ensuring the compliance "tone at the top" is adopted throughout the organization. "The [DOJ's] Evaluation of Corporate Compliance Programs makes clear, a company must have more than simply a good 'Tone-at-the-Top’; it must move down through the organization from senior management down to middle management and into its lower ranks," Fox notes.