Time to Shift to “Conduct from the Top”

In a commentary for FCPA Blog, KPMG's Annabel Reoch and Tom Barrett write about an evolution in the principle of setting the right “tone at the top” to shift more attention to demonstrating the right “conduct from the top.” The former is regarded as the most important principle in the prevention and detection of bribery and unethical conduct, but the latter is more active.