Tag: middle managers

Categories
Blog

The Missing Link in Compliance: Building an Effective Advice Function

In a best-practices compliance program, a policy explains the rules. Training can introduce the risks. But when an employee faces an unfamiliar request, they still need to know what to do now, before making a commitment that changes everything. The question may arrive while a customer waits, a payment is pending, or a team prepares to launch a product. At that moment, “please consult the policy” may identify a resource without resolving the decision. Compliance should equip people before they improvise, not merely evaluate their improvisation afterward.

Your corporate compliance function should routinely advise employees on all compliance-related issues. But when did you last evaluate this ‘advice function’ as part of the compliance program? Training should help employees recognize when a question exists. Guidance should help resolve it in the actual circumstances.

A mature design therefore asks where important decisions occur, who needs help, and how quickly your compliance function can respond. A small company may use a straightforward contact arrangement with clear backups. A larger organization may need specialist routing across functions and time zones to ensure complete coverage. Neither should depend entirely on employees knowing the right person personally.

Make the route visible in the workflow where the question arises. An approval screen, travel process, vendor request, or data-sharing step can direct the user to the right assistance without requiring a search of the entire intranet.

The Corporate Translation: A Question Before the Commitment

Consider a hypothetical business development team preparing an important demonstration. An external platform could make the presentation more compelling. A team member suggests uploading records from an existing customer so the demonstration reflects real business conditions. The deadline is tomorrow. The platform has not been reviewed for that use.

One employee remembers the company’s data-handling training but is unsure whether a limited demonstration falls within the existing rules. The employee needs an answer before the upload, not a general reminder the following week. A useful response identifies the immediate boundary, the facts requiring review, and a workable alternative. For example, the adviser may explain that company policy requires pausing the proposed upload while the team uses approved synthetic demonstration data.

The commercial objective continues through an authorized route. The unresolved platform assessment remains a separate task with an owner. That is preventive compliance: reducing uncertainty while there is still an opportunity to choose a better course.

Distinguish Advice, Approval, and Reporting

Employees should not have to understand the company’s organizational structure before asking for help. But the company must distinguish what happens after the question arrives. Compliance advice and counseling explain expectations and possible courses of action. Approval authorizes a defined activity within delegated authority. Reporting communicates a concern that may require assessment or investigation. One conversation can involve all three. It should not silently substitute one for another.

In the demonstration example, explaining the synthetic-data option does not approve the external platform for unrestricted use. A security assessment may inform the decision without completing a contractual review. A disclosure that records have already been uploaded requires a different response than a prospective question. State the status clearly. Identify what is authorized, what is prohibited under the applicable requirements, what remains unresolved, and who owns the next decision. Do not describe every advice request as a suspected violation. At the same time, do not leave credible allegations in an informal advice queue because the original employee selected the wrong category.

Ask for the Facts That Change the Answer

A useful intake process gathers enough information to understand the decision without unnecessarily complicating the request. Ask what the employee proposes to do, which parties are involved, what has already happened, and when the next irreversible step occurs. Identify the relevant information, payment, benefit, representation, or commitment.

Then ask what could change the answer. In our hypothetical, that may include the type of records, existing permissions, platform terms, intended audience, and whether the information would remain stored afterward. Let the employee say a fact is unknown. An intake form should not force a confident answer where none exists.

A compliance professional should avoid collecting unrelated personal information or demanding a full investigation before providing preliminary guidance. Begin with a safe interim direction where appropriate, then assign the additional review. But a compliance professional should also test the claimed deadline. Some deadlines reflect genuine operational needs. Others reflect a late request or an assumption that nobody can change the schedule.

Make the Response Usable

Your employee needs a response they can act on, not one they can only admire for its precision. Explain the concern in business terms. Identify the action that may proceed and the action that must wait—state any conditions, the responsible decision-maker, and what new facts would require reconsideration. In our hypothetical, a practical response might confirm an approved demonstration method, identify the owner of the external-platform review, and explain that permission for the demonstration does not authorize later customer-data uploads.

Preserve the reasoning proportionately. A brief written answer may be enough for a straightforward question. A consequential decision may require a fuller record and formal approval. Do not use conditional language that nobody owns. “Proceed once all requirements are satisfied” is incomplete unless someone knows which requirements apply and who verifies completion. Yes, you knew I would slip in Document Document Document at some point.

Give Advisers Authority and Reliable Backup

A corporate compliance function needs authority, access, and resources to influence decisions before risk is accepted. Timely advice is one way to operationalize that independence. A compliance professional should know when it can answer directly and when another function must decide. Give advisers escalation routes for unresolved legal, technical, operational, and commercial questions.

Provide backup for absence and specialist coverage. A program that relies on one expert to answer every urgent message recreates key-person risk. Define what happens when business and compliance disagree. Preserve the competing assessments and route them to the authorized decision-maker. Do not allow repeated requests to different advisers to produce an undocumented approval search.

Maintain an appropriate record of previous advice so that the next adviser can see the relevant history. Restrict sensitive information and involve counsel when legal privilege or other protections may apply; do not promise protections the process cannot guarantee. Employees should be able to trust the service without being told that every conversation is secret or every answer is final.

Measure Helpfulness, Not Just Response Speed

A fast acknowledgment is useful. It is not the same as a resolved question. Measure time to an actionable response, time to final resolution, and reasons for delay. Separate time spent waiting for missing information from time lost because the request had no owner.

Review whether employees understood the answer and followed the approved path. Sample a small number of completed requests and compare the guidance with the subsequent transaction or activity. Also look for unnecessary complexity. If routine questions repeatedly require several functions to restate the same policy, clarify the process rather than celebrating the volume of collaboration.

The 2024 Evaluation of Corporate Compliance Programs asks whether employees know when to seek compliance advice, how to do so, and whether they are willing to do so. Availability alone does not answer either question. Use feedback carefully. Satisfaction is relevant, but a correct refusal may disappoint the requester. Conversely, a popular answer may be insufficiently supported. Assess the reasoning, the clarity of the next step, and the result. Speed belongs in that assessment but should not dominate it.

Managers Determine Whether Asking Feels Practical

Imagine an employee using the advice service correctly, only to hear from their manager that the question should never have been raised. The channel exists. The local message defeats it. A culture of speaking up exists only if it’s matched by a culture of listening up.

Managers should model asking early, providing necessary facts, and responding constructively when the answer changes the plan. Include those behaviors in manager training and leadership expectations, and evaluate them through real examples. Give teams protected time for review. A manager cannot repeatedly create last-minute commitments and then treat the resulting control discussion as evidence that compliance is slow.

Equally, compliance should examine its own delays. An inaccessible or inconsistent service should not place the burden of its design failures on the employee. Train managers to receive uncertainty without demanding an immediate conclusion. “Let us establish the facts before we commit” is a useful leadership response. Where concerns involve the manager, provide another route. Advice should not require the permission of the person whose instruction is being questioned.

Turn Repeated Questions into Better Design

An advice log can reveal where policies, training, and workflows leave employees uncertain. Repeated questions about one approval may indicate vague or imprecise instructions or even an unclear policy. Questions arriving after commitments may indicate that the control sits too late in the process. Different answers to the same facts may indicate that advisers need alignment. Treat those patterns as hypotheses to investigate, not conclusions to impose.

NIST SP 800-50 Revision 1 approaches cybersecurity and privacy learning through audience needs, behavior change, evaluation, and improvement. Applying that learning-cycle logic to compliance guidance can help connect recurring questions with targeted program changes. For the demonstration team, a useful improvement might be an approved dataset library and a clear route for reviewing external tools. That would address the underlying business need rather than simply repeat the prohibition. Test the revision with the people performing the work. Can they find the approved materials? Do the materials meet the legitimate purpose? Do they know when a different use needs review?

The Compliance Takeaway

The bottom line for a compliance professional is to recognize the situation, explain the issue, provide usable help, and do so before the critical encounter. For companies, that means making advice available where decisions happen. It means clear ownership, appropriate expertise, reliable escalation, and answers that distinguish permission from unresolved questions.

The business should not need a heroic employee to find the one person who understands the issue. Nor should compliance require a crisis before it becomes accessible.

Return to the demonstration. The employee asked before uploading the records. The adviser identified a responsible alternative. The team continued its work without treating the deadline as permission to ignore the concern. That is the result to design for.

The best time to explain the antidote is before someone needs to recover from the exposure.

Categories
Blog

Ted Lasso Week: Part 4 – Roy Kent: The Compliance Power of the Middle Manager

Season 4 of Ted Lasso is out. Matt Kelly reposted a blog he wrote during the original run of the series, and he and I did a deeper dive into the show and its popularity for compliance professionals in an episode of Compliance into the Weeds. I decided to take a deep dive into five characters from the show and use them to explore compliance topics. Over five blog posts, I have considered Manager Ted Lasso, Assistant Manager Nate Shelley, player and later coach Roy Kent, and social media influencer Keeley Jones. Today in Part 4, I consider the sometimes painful transition of an aging sports star into middle-management coaching.

In Part Three, Nate Shelley demonstrated the danger of promoting technical talent without preparing or monitoring the new manager. Roy Kent provides the counterpoint. He is demanding, impatient, and frequently intimidating, but he understands that leadership happens close to the work. Ted can articulate Richmond’s values. Rebecca can provide authority and resources. Roy determines whether those values survive contact with the locker room. He corrects behavior, confronts stars, coaches struggling employees, and translates general expectations into specific action.

For compliance professionals, Roy illustrates the power of the middle manager. He also shows the risk. The same informal authority that can strengthen culture can magnify poor judgment when it is not bounded by self-awareness, escalation, and accountability.

Authority Exists Before the Title

Roy begins the series as Richmond’s captain, not a member of management. Yet his teammates watch him, follow him, and adjust their behavior around him. He has informal authority, which often matters more than the organizational chart.

In “Trent Crimm: The Independent” (Season 1, Episode 3), Ted recognizes that Jamie Tartt and other players are bullying Nate. Rather than solve the problem solely through formal coaching authority, Ted pushes Roy to act. Roy confronts Jamie and forces the locker room to change. That is the tone in the middle. Employees often look to a respected supervisor, veteran, or peer leader to determine whether the code of conduct is real. If that person laughs at an offensive joke, ignores a control override, or protects a top performer, the policy loses. If that person intervenes, the standard gains operational force.

The DOJ Evaluation of Corporate Compliance Programs (ECCP) directs prosecutors to examine how managers at all levels encourage or discourage compliance through their words and actions. Compliance leaders therefore need to identify informal influencers, not merely designated supervisors. On this point, the ECCP states, “it is important for a company to create and foster a culture of ethics and compliance with the law at all levels of the company. The effectiveness of a compliance program requires a high-level commitment by company leadership to implement a culture of compliance from the middle and the top.” Culture travels through both. The ECCP goes on to state “[t]he company’s culture of compliance, including awareness among employees that any criminal conduct, including the conduct underlying the investigation, will not be tolerated.”

Standards Must Apply to Stars and to the Manager

Roy’s credibility comes partly from his willingness to confront Jamie, Richmond’s most talented player. He refuses to accept the idea that performance excuses selfishness or abuse. That is a central compliance principle. Standards that bend around revenue generators and star executives are not standards.

Roy faces the same test personally in “All Apologies” (Season 1, Episode 9). His age and injuries have reduced his performance, but his identity is tied to being captain and playing every match. When Ted decides to bench him, Roy initially resists. He ultimately reports for training in the reserve bib and supports the team. The decision matters because accountability becomes credible when the influential employee accepts the rule applied to everyone else. Roy does not enjoy the outcome, but he demonstrates that status does not confer immunity.

Effective Coaching Diagnoses the Cause

In “The Hope That Kills You” (Season 1, Episode 10), Roy selects Isaac McAdoo as the next captain. By “Rainbow” (Season 2, Episode 5), Isaac is struggling under the weight of that role. Ted asks Roy for help. Roy does not respond with another motivational speech or a threat. He takes Isaac to the neighborhood pitch where Roy learned to play and places him in an informal match. The intervention helps Isaac rediscover that football is a game he loves.

This is root-cause analysis at the individual level. The visible problem is poor performance. The underlying issue is that responsibility has displaced purpose and confidence. Roy changes the environment, observes Isaac, and chooses an intervention connected to the cause. The compliance application is substantial. When an employee misses a control, a manager should not automatically assign retraining. The cause may be an unrealistic target, conflicting procedures, poor system design, inadequate staffing, fear of escalation, or a supervisor who rewards shortcuts. Training cannot repair a misaligned incentive. Discipline cannot correct an unusable process.

Coaching Can Turn a Risk Into an Asset

Roy’s relationship with Jamie becomes his strongest management case. He begins by confronting Jamie’s entitlement. In “Man City” (Season 2, Episode 8), after Jamie finally strikes back at his abusive father, Roy recognizes the pain beneath the conduct and embraces him. The response is neither a lecture nor an endorsement of violence. It is a manager recognizing that the employee needs support before instruction.

In “4-5-1” (Season 3, Episode 3), Jamie asks how he can become better than Zava. Roy offers to train him. The work continues through “Sunflowers” (Season 3, Episode 6), when their training in Amsterdam becomes reciprocal, and Jamie teaches Roy to ride a bicycle. Roy does not lower the standard for Jamie. He gives him the discipline, attention, and feedback needed to meet a higher one. This is what good remediation should accomplish. It should protect the organization while creating a credible path for behavioral improvement.

Managers need tools for these conversations: clear expectations, documented feedback, measurable improvement goals, support resources, escalation thresholds, and follow-up. Candor without structure can become hostility. Compassion without standards can become avoidance. Roy is most effective when he combines both.

Informal Power Can Also Amplify Bad Judgment

Roy is not a flawless compliance model. In “Big Week” (Season 3, Episode 4), he and Coach Beard show the players security footage of Nate tearing the “BELIEVE” sign, despite Ted’s decision not to use it as motivation. The team becomes enraged, loses discipline, receives multiple red cards, and falls to West Ham. Roy intends to motivate. He instead weaponizes internal security footage and emotional injury.

The failure offers three lessons. First, managers must understand the limits of delegated authority. Silence or ambiguity from senior leadership is not permission to bypass its stated judgment. Second, incentives built on anger can produce foreseeable misconduct. Third, a result-driven culture can make an improper method appear acceptable until the damage becomes visible.

Roy’s training methods can also cross from demanding into unsafe or humiliating, as the red-string exercise in “The Strings That Bind Us” (Season 3, Episode 7) demonstrates. A strong manager should challenge employees. The organization must still set boundaries around safety, dignity, and acceptable conduct. This is why middle-management training cannot be limited to explaining policy. Managers need scenario-based practice on investigations, privacy, retaliation, discipline, escalation, health and safety, conflicts, and the use of employee information.

The Best Managers Remain Coachable

Roy’s development is possible because he gradually accepts that leadership does not require invulnerability. In “So Long, Farewell” (Season 3, Episode 12), he joins the Diamond Dogs, asks whether people can change, and later begins therapy. He becomes Richmond’s manager, but his promotion is framed as the next stage of development, not proof that the work is finished.

That distinction matters. Organizations often treat promotion as validation rather than increased risk. The best managers remain open to feedback, seek guidance, acknowledge uncertainty, and use available expertise. Middle managers are a critical source of that information. They should not filter out bad news to protect their numbers. Boards and executives should ask whether managers escalate emerging risks, whether the organization rewards such escalation, and whether retaliation or fear is blocking the flow of information.

Questions for CCOs

Roy’s journey should prompt five questions:

  1. Who are the organization’s informal culture carriers, and how are they engaged?
  2. Are managers evaluated and rewarded for how they achieve results, not only for the results themselves?
  3. Do managers know how to diagnose root causes, escalate concerns, and document behavioral coaching?
  4. Are high performers subject to the same conduct standards as everyone else?
  5. Does manager training distinguish productive candor from intimidation, retaliation, humiliation, and unsafe pressure?

Roy Kent demonstrates that middle managers are the operational heart of compliance. They make standards visible, detect weak signals, and decide whether employees experience accountability as fair. Compliance cannot succeed around them. It must succeed through them.

Next in the Series: Keeley Jones and Governance Under Pressure

Roy’s challenge is translating established values into frontline behavior. Keeley Jones faces the next organizational stage: building a business, accepting investor capital, managing employees, and preserving independence while personal and commercial pressures converge. Join us in our series finale, where we will examine founder risk, conflicts of interest, privacy, third-party influence, and why governance must grow as quickly as the company it is designed to protect.

Categories
FCPA Compliance Report

FCPA Compliance Report – Middle Managers Are the Key – Evie Wentink’s Evolution in Compliance

Join Tom Fox as he welcomes back Evie Wentink back to the FCPA Compliance Report. Evie shares her journey from a compliance professional to an innovator in the field, discussing her unique approach to compliance training and the role of middle managers. With nearly two decades of experience, Evie has transformed her career by leveraging social media to create engaging content that inspires compliance professionals worldwide. Discover how Evie’s innovative strategies are reshaping the compliance landscape and learn about her new venture, Ethical Edge Experts LLC.

Key takeaways:

– 🌍 Embrace change and see the world beyond your keyboard.

– 💡 Innovation in compliance through social media and engaging content.

– 🏢 The critical role of middle managers in compliance programs.

– 📚 The importance of continuous learning and professional growth.

– 🎯 Selling compliance by making it personal and relatable.

Key highlights:

  • Embracing Change and Innovation
  • Training and the Role of Middle Managers
  • Bridging the Gap in Compliance Perspectives
  • Utilizing Social Media for Compliance Engagement
  • The Importance of Being Coachable
  • Ethical Edge Experts LLC

Resources:

Evie Wentink

🔸 LinkedIn: Evie Wentink

🔸 Consulting Firm: Ethical Edge Experts

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

For more information on the use of AI in Compliance programs, my new book, Upping Your Game. You can purchase a copy of the book on Amazon.com

Categories
Compliance Into the Weeds

Compliance into the Weeds: Examining the Impact of Reducing Middle Management on Corporate Culture

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly discuss the implications of reducing the number of middle managers in corporate America.

Kelly’s blog post, inspired by a Wall Street Journal article, serves as the foundation for a broader discussion on how the reduction of managers impacts corporate culture, employee dynamics, and compliance programs. They explore the reasons behind this trend, such as the desire for agility or cost-cutting, and its effects on communication, institutional knowledge, and the role of compliance officers. They also explore potential solutions, including the use of AI, enhanced training, and adaptive compliance strategies, to mitigate the risks associated with fewer middle managers.

Key highlights:

  • Corporate America’s Managerial Shift
  • Implications for Corporate Culture
  • AI and Compliance Solutions
  • Institutional Knowledge and Risks
  • Compliance Takeaways and Final Thoughts

Resources:

Matt on Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards for podcast excellence.

Categories
Daily Compliance News

Daily Compliance News: June 5, 2025, The Asset Cap Lifted Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News. All from the Compliance Podcast Network. Each day, we consider four stories from the business world: compliance, ethics, risk management, leadership, and general interest, all of which are relevant to the compliance professional.

Top stories include:

  • Wells Fargo has an asset cap lifted. (WSJ)
  • More Millennials and Gen Zers as middle managers. (Business Insider)
  • Swiss banking reforms for UBS are announced. (FT)
  • More spying and corruption at EcoPetrol. (Bloomberg)
Categories
Compliance Tip of the Day

Compliance Tip of the Day – Empowering Middle Managers to Drive Compliance Transformation

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements. Whether you’re a seasoned compliance professional or just starting your journey, we aim to provide bite-sized, actionable tips to help you stay on top of your compliance game. Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law. Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

How a compliance function can use middle managers to drive real transformation in a compliance program.

For more on this topic, check out The Compliance Handbook, a Guide to Operationalizing Your Compliance Program, 6th edition, which was recently released by LexisNexis. It is available here.

Categories
Blog

Muddle in the Middle Week: Part 5 – Empowering Middle Managers to Drive Compliance Transformation

We are at the end of this week’s exploration of how middle managers can elevate your organization’s compliance regime. While I named the week’s series Muddle in the Middle, I hope that by this Part 5, you have seen how powerful middle managers can be in making a compliance program run more effectively. I want to end this week by examining how a compliance function can use middle managers to drive real transformation in a compliance program.

As compliance professionals, we continuously strive to enhance our corporate compliance programs to navigate an increasingly complex regulatory landscape. While historically prevalent, the traditional methods of top-down directives paired with bottom-up execution in compliance have shown significant shortcomings. Indeed, according to recent studies highlighted by Michael Mankins and Patrick Litre in their article “Middle Managers Should Drive Your Business Transformation,” fewer than one in eight organizational transformations achieve sustained success without strong middle manager support.

Middle managers are frequently underestimated and often miscast as bureaucratic gatekeepers who slow down processes and resist innovation. However, the truth could not be further from this stereotype. Strategically positioned between executive leadership and frontline teams, middle managers possess unique capabilities essential to driving meaningful, lasting compliance transformations. Their role is vital today as compliance evolves beyond basic regulatory adherence into a strategic business partnership and ethical stewardship.

The authors advocate strongly for a new transformation model powered from the middle outward. I drew on this article to consider how compliance teams can leverage these insights, translating business transformation principles into effective compliance transformation strategies. Here are five essential lessons for compliance professionals:

Lesson 1: Select and Deploy Your Best Talent for Compliance Initiatives

Not all middle managers have an equal impact. The best compliance outcomes come from deploying your most competent middle managers as transformation leaders. At Amgen, senior leadership intentionally chose top-rated middle managers to lead critical business initiatives, dedicating these managers exclusively to the transformation process without distractions. Compliance officers should similarly identify middle managers with a strong record of integrity, clear decision-making abilities, and the respect of their teams, placing them at the forefront of compliance improvement projects. By deploying these standout individuals, compliance initiatives are far more likely to achieve the credibility, engagement, and results that compliance projects demand.

Lesson 2: Empower Middle Managers to Actively Sponsor Compliance Change

Effective compliance transformation hinges on middle managers executing instructions and actively sponsoring the change. The case of bioMérieux is instructive: the company succeeded in integrating a major business unit largely because it empowered middle managers to implement significant strategic shifts, ensuring that they had clearly defined objectives, adequate resources, and genuine authority to initiate change.   Compliance professionals must replicate this model. Middle managers in compliance roles must be empowered to advocate for and actively shape compliance policies, procedures, and cultural initiatives. They need the autonomy and support to tackle complex compliance challenges and facilitate meaningful dialogue across organizational hierarchies.

Lesson 3: Cultivate a Culture That Rewards Bold Compliance Actions

Transformative compliance isn’t about incremental tweaks; rather, it is about courageous, forward-looking innovation. When T-Mobile sought radical improvement in its customer experience, leadership directed their teams broadly: “Do what’s needed to rock the world.” This bold mandate, supported by recognition and reward, substantially improved customer satisfaction metrics. Compliance leaders must likewise cultivate environments where middle managers are rewarded for bold, creative, and proactive compliance thinking. Recognizing and promoting innovation within compliance signals clearly to all employees that compliance is not just about risk avoidance but about creating sustainable business value through ethical leadership and integrity.

Lesson 4: Shift Middle Management Focus from Oversight to Facilitation

Compliance middle managers often find themselves buried under administrative tasks that could easily be automated, detracting from their ability to lead strategic initiatives. The authors stressed that organizations must refocus middle managers on strategic initiatives, enabling them to leverage their unique insights and skills in transformative ways. In compliance terms, this means reducing the burden of routine oversight and increasing opportunities for middle managers to facilitate skill development, ethical decision-making workshops, and collaboration across diverse teams. Organizations can fully utilize their expertise in navigating complex ethical landscapes and regulatory environments by freeing compliance managers from lower-value tasks.

Lesson 5: Align Training and Development to Enable Compliance Transformation

Finally, effective compliance transformation requires an ongoing commitment to training middle managers in the soft skills necessary for ethical leadership and the technical knowledge required to manage emerging compliance risks. Amgen’s example clearly illustrates how carefully integrated leadership development programs with strategic initiatives provide managers with the tools to drive transformation effectively. Compliance teams must ensure their training programs comprehensively address evolving compliance demands, emphasizing leadership, coaching, conflict resolution, and critical analytical thinking. Middle managers with robust training and clearly defined career progression pathways become highly motivated compliance champions.

The Cornerstone of Sustainable Compliance

Compliance is at a critical inflection point. The challenges are becoming more complex, the regulatory demands are becoming more intricate, and stakeholder expectations are higher than ever. Traditional approaches no longer suffice. Effective compliance transformation must harness the strategic capabilities of middle managers who sit uniquely at the intersection of organizational strategy, operational reality, and ethical culture.

Middle managers are not merely policy executors; they must be active architects of compliance strategy. Compliance professionals can significantly elevate their programs’ effectiveness and sustainability by identifying and empowering top talent, facilitating bold compliance innovations, shifting managerial focus, and providing targeted development.

Let the insights from Amgen, bioMérieux, and T-Mobile guide your compliance journey. Embrace the power of middle managers, transforming them from operational gatekeepers into strategic compliance catalysts. Compliance professionals who understand and act on these lessons will undoubtedly lead their organizations into an era of resilient ethical leadership and sustainable compliance excellence.

I hope you have enjoyed this week’s focus on middle managers and how compliance professionals can use them to drive compliance transformation and messaging while leading the effort to do business ethically and in compliance.

For more on this topic, check out The Compliance Handbook, a Guide to Operationalizing Your Compliance Program, 6th edition, which LexisNexis recently released. It is available here.

Categories
Compliance Tip of the Day

Compliance Tip of the Day – Middle Managers as the Eyes and Ears of Compliance

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements. Whether you are an experienced compliance professional or just beginning your journey, our goal is to offer concise, practical advice to keep you at the forefront of compliance. Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to ensure your organization remains compliant with the law. Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

Today, we will discuss how middle managers can serve as compliance’s primary observers and auditors.

For more on this topic, check out The Compliance Handbook, a Guide to Operationalizing Your Compliance Program, 6th edition, which LexisNexis recently released. It is available ⁠here⁠.

Categories
Blog

Muddle in the Middle Week: Part 4 – Middle Managers as the Eyes and Ears of Compliance

We continue exploring how a corporate compliance function can use middle managers to make compliance more effective. This is perhaps the most dynamic era for business, with sweeping reengineering, digitization, and agile initiatives that have dramatically transformed the job of managers. Change has come in three dimensions: power, skills, and structure. Managers now have to think about making their teams successful rather than being served by them, coaching performance, not overseeing tasks, and leading in rapidly changing, more fluid environments.

No role has shifted more than that of the middle manager, who has undergone significant transformations. Today’s managers are no longer task overseers; they are increasingly expected to serve as vital conduits for compliance, embodying and advocating ethical standards across organizational layers. A recent article from Harvard Business Review, “Managers Can’t Do It All” by Diane Gherson and Lynda Gratton, lays bare the mounting pressures managers face and underscores a compelling necessity: reinventing the middle manager role to navigate contemporary workplace demands effectively.

These shifts have piled more responsibilities onto middle managers, requiring them to demonstrate new capabilities. The authors found that research shows that most middle managers struggle to keep up. More importantly, they posit a crisis is looming, if not already here, for middle managers. Some organizations, however, are heading it off by reimagining the role of middle managers. This article looks at three factors that have helped middle managers develop new skills, rewire systems and processes to support their work better, and even radically redefine the role.

Despite these pressures, the role of middle managers as compliance champions has become even more critical. Compliance officers rely on middle management to uphold standards and monitor and report potential risks. Ensuring these managers understand and embrace their evolving responsibilities is no longer optional; compliance is imperative.

Compliance professionals are uniquely positioned to leverage these insights. Middle managers, after all, play a crucial role in compliance frameworks, acting as frontline observers who detect and escalate potential ethical and compliance risks. Compliance teams must evolve their training methods and operational expectations to equip these pivotal figures better. In part 4, we explain how middle managers can work to be the eyes and ears of compliance.

Training Middle Managers to be the Eyes and Ears of Compliance

Drawing from these organizational examples, compliance leaders can consider several key lessons to empower middle managers effectively:

  • Shift Mindsets from Oversight to Coaching
  • The authors pointed to Standard Chartered’s initiative in developing its middle managers as “people leaders,” which underscores a vital transition: moving from traditional supervisory roles to ones of active coaching. Compliance professionals should train middle managers to adopt a coaching mindset that focuses less on direct oversight and more on empowering and guiding their teams through supportive, ongoing feedback.

When middle managers learn to coach, they naturally cultivate environments where openness and transparency thrive. Employees feel comfortable bringing compliance concerns forward and secure in knowing their managers will support rather than penalize them for raising issues.

  • Invest in Managerial Accreditation and Continuous Development
  • Next, the author looks at IBM’s strategic approach, which highlights the impact of investing in robust accreditation and continuous learning programs for managers. Compliance officers can replicate this model by creating certifications or licenses tied to compliance competencies. Courses in ethical decision-making, risk identification, and fostering psychological safety can empower middle managers to address compliance concerns before they escalate proactively.

A dedicated compliance accreditation signals clearly that your organization prioritizes compliance skills as essential managerial capabilities, helping ensure managers remain attuned to the shifting compliance landscape.

  • Utilize Digital Tools to Streamline Compliance Activities
  • The authors noted that IBM’s use of artificial intelligence to remove administrative burdens from managers serves as a powerful example of compliance functions. By automating routine compliance tasks, such as approvals or routine monitoring, compliance professionals can free managers to focus on more significant compliance issues, including fostering a culture of integrity.

Equipping managers with digital tools for real-time guidance, instant risk assessments, and compliance insights allows them to swiftly spot compliance risks and report potential red flags without getting bogged down in administrative details.

  • Clarify Roles by Splitting Responsibilities
  • The authors found that Telstra’s innovative management structure, clearly dividing “leaders of people” from “leaders of work,” is instructive for compliance. Clearly delineating roles within compliance can relieve managerial overload and sharpen compliance effectiveness. As “leaders of people,” middle managers can concentrate on building ethical cultures, supporting compliance education, and nurturing open communication about ethical concerns.

In contrast, “leaders of work” roles can ensure compliance measures are embedded directly into day-to-day operations and workflows. Clear role definitions help middle managers understand how they contribute to the compliance mission, enhancing accountability and effectiveness.

  • Foster Community and Peer-to-Peer Learning Among Managers
  • One particularly valuable strategy highlighted by Standard Chartered involves creating robust managerial communities. Compliance professionals should replicate this practice by establishing regular forums where managers can share compliance experiences, insights, and best practices. Peer-to-peer discussions can significantly enhance managers’ awareness and responsiveness to compliance issues.

Community-focused approaches to addressing common challenges, such as diversity initiatives or ethical dilemmas, help embed compliance deeply into the organizational culture. Compliance becomes a shared responsibility rather than merely an isolated regulatory function.

Strengthening Compliance through Empowered Middle Management

Once perceived merely as conduits for executive directives, middle managers must now become active facilitators of compliance culture. Compliance professionals face the critical task of equipping these managers to navigate their evolving roles adeptly. The authors’ article provides powerful insights and practical models to guide this transformation.

Organizations that invest wisely in their middle managers, explicitly developing them as proactive compliance champions, will discover they possess invaluable partners positioned perfectly to detect and address compliance risks early. In our digitized, agile, and remote workplace, it’s not enough for compliance professionals alone to manage compliance risks; effective management relies on empowering managers to recognize, respond to, and ultimately embody a culture of compliance.

As the authors suggest, transformative managerial roles are not merely advantageous but essential for thriving in today’s new world of work. Compliance professionals who internalize these lessons and train middle managers to become proactive stewards of compliance will enhance organizational integrity, reduce risks, and strengthen their company’s ethical foundation.

I hope you join me tomorrow when I consider empowering middle managers to drive compliance transformation.

For more on this topic, check out The Compliance Handbook, a Guide to Operationalizing Your Compliance Program, 6th edition, which LexisNexis recently released. It is available here.

Categories
Compliance Tip of the Day

Compliance Tip of the Day – Elevating Compliance Through Connected Middle Managers

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements. Whether you are an experienced compliance professional or just beginning your journey, our goal is to offer concise, practical advice to keep you at the forefront of compliance. Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to ensure your organization remains compliant with the law. Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

Today, we look at how compliance professionals can tap into these connected middle managers to elevate compliance and the strategy of ethical business conduct.

For more on this topic, check out The Compliance Handbook, a Guide to Operationalizing Your Compliance Program, 6th edition, which LexisNexis recently released. It is available here.