Murmur in the Middle (Management)

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:

  • Define your target audience.  Middle management is a broad term, encompassing anyone overseeing employees who is not in the C-suite.  To effectively work with middle management, specifically define who you want to engage.  Do you want to work with regional managers overseeing sales in particular countries?  Do you want to reach out to factory managers who oversee day-to-day operations and interface with government officials doing inspections?  By targeting a narrow and defined group of managers, you will be able to tailor your message and the tools you provide to specifically address actual risks that these middle managers will help you mitigate.


  • Let them know how and why they are important.  Don’t just tell middle managers that they now must do more to help compliance efforts – highlight the vital role they play in helping the company avoid financial and reputational harm and in creating an ethical culture, which in turn will drive business.  Let them know how they will be helping the world with their efforts – whether it be fighting corruption that harms economic growth, protecting women from human trafficking, or preventing terrorists from accessing funds.


  • Ask them to tell you what you should worry about.  Patterns of misconduct often occur that the compliance department can’t anticipate.  Middle managers are in the best position to let you know about those potential risks so that you can appropriately address them.  Moreover, asking middle managers for their opinions and advice is a crucial part of engaging them in your compliance efforts.  If managers feel they are being heard and that their role is important, they are more likely to vigorously engage in compliance and ethics.


  • Be specific about how they can help.  The most effective way to engage middle management is to be specific as to what they need to do.  Ask them to let you know if they see specific red flags or misconduct.


  • Establish an effective line of communication.  Reach out to your target audience consistently.  If your middle managers use email, a listserv of just these managers is the easiest way to reach them.  If they all work in one geographic location or gather regularly for company conferences, an in-person visit might be the most effective way to get your message out.  Communicate with the middle managers regularly (be it monthly, quarterly or annually) and make sure that they know how to reach you to ask questions or report concerns.


  • Involve executive management.  A message from the CEO or other upper management can effectively communicate to managers the importance of engaging with the compliance department.  This is particularly important for managers who hope to advance within the company and want to know that their efforts are appreciated and will be rewarded by the company.


  • Praise their compliance efforts.  Everyone likes to be told they are doing a good job.  If possible, compliance efforts should be included in managers’ performance reviews, which not only emphasizes the importance of compliance, but incentivizes them to meet compliance goals.  If you have a quarterly email or newsletter you send out to these managers, you might want to consider selecting a manager each time as Compliance Manager of the Month (or Quarter or Year), showing their picture and asking them a few questions about how they contribute to the company’s ethical culture. 


  • Don’t bombard them with additional tasks.  Finally, while you want to engage middle management, be cognizant of the fact that their job is operational and managerial, not purely compliance.  Keep your expectations reasonable given their other work duties and let them know that you respect their time.

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

 Diana Trevley can be contacted at