May 14, 2009
We'll post the second in our cost-effective compliance series tomorrow, --addressing how anti-bribery compliance can be made relevant to managers in the field. But first, I wanted to post the best description of “tone at the top” that I’ve heard to date.
Earlier today, I moderated a panel in Virginia that included Howard Sklar, Vice President of Compliance & Ethics at American Express. The panel was asked to discuss ethical leadership and "tone at the top". Howard opened with this definition:
“Tone at the top is a visible willingness by senior management to let values drive decisions, to prioritize those values above other factors—including financial results—and to expect all others in the organization to do the same.”
Visibility. Values. Priorities. Expectations. It’s all there.