Murmur in the Middle (Management)

The following is a guest blog post by Diana Trevley, Spark Compliance Consulting’s West Coast Director.

Although “the tone from the top” gets most of the press, for most compliance teams the “murmuring in the middle” represents the greatest challenge for engagement.  In a surprising number of litigations and government actions, long before the case ever reached the courthouse, the whistleblower reported what he or she saw or suspected to a line manager – and yet nothing was done.  After the company took no action, the whistleblower then went to the government – or filed a lawsuit – leaving the company in a far more precarious position than if the issue had been addressed after it was first reported internally. 

Perhaps the middle manager didn’t think the issue was important?  Maybe the he or she did not know how to appropriately escalate the issue?  Or perhaps the middle manager was concerned that it would reflect badly on him or her? 

Middle managers are a crucial compliance ally.  They’re the boots on the ground – the people who oversee what is going on at an operational level on a day-to-day basis.  The nature of their position puts them in a powerful position to influence the culture of a company, communicate risks to the compliance department, and to address issues of misconduct before things spin out of control.  Having middle management onboard with your compliance objectives and initiatives will significantly strengthen your program.  Here are some ways to engage with the sometimes messy business of middle management:








By implementing these strategies, you can move managers’ messaging on compliance from murmuring to mighty.  

 Diana Trevley can be contacted at 

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