Beyond the Tone at the Top: Why Mood and Vibe Matter in Compliance and Ethics

We often discuss the importance of the “tone at the top” and assume that ethics will cascade to the rest of an organization. Compliance and ethics culture can evaporate long before it ever reaches frontline teams. There are two essential filters between the top and frontline teams: the mood in the middle and the vibe at the bottom. Compliance professionals must simultaneously ensure that executives set the tone for ethics and understand how the culture is translated, reshaped, and sometimes distorted at every layer of the organization. Ensuring that ethics are fully integrated within an organization will serve organizations well as risk environments evolve.

Let’s define the layers and the all-important filters. The tone at the top refers to ethical messaging and behavior modeled by executive leadership. The mood in the middle describes how middle management interprets and implements those values. And the vibe at the bottom is how frontline employees experience, internalize and reflect those norms in their behavior.

The Mood in the Middle

Middle managers are critical for translating corporate integrity. If a manager misunderstands or deprioritizes compliance, ethical priorities get watered down or filtered out. Managers must often balance ethics and achieving goals and objectives; they may not have the incentives, time, or tools to lead with an ethics-first approach. Balancing ethics with other goals becomes more complex if leadership messaging is vague or competes with different priorities.

The Vibe at the Bottom

Frontline employees experience compliance and ethics through peer dynamics, daily decisions, and perceived risk. Compliance is compromised if the view of ethics at this level is cynical, performative, or motivated by fear. Even the best policies cannot outpace attitudes, which may lead employees to distrust and disregard internal systems. 

The key to understanding ethics at this layer is essential for compliance teams. A compliance team that has the trust of frontline teams must create meaningful and safe feedback channels. Compliance teams can create meaningfulness and safety by:

• Using anonymous surveys;

• Implementing quarterly listening sessions; and

• Seeking out and highlighting compliance champions or ethics ambassadors. 

The compliance team's role is to connect all three organizational layers. The compliance team can interpret ethical priorities and ensure they are translated consistently. This requires the compliance team to balance an enforcement role with a messaging role. Compliance teams should collect information from across the organization, design policies and procedures for different roles, and build relationships that last longer than annual training. Ethics compliance teams connect all three layers. The goal is to identify gaps and misalignment between tone, mood, and vibe. Tone sets the stage. Mood and vibe determine performance; reading the whole room is critical to creating an organization-wide culture of ethics.

Michele Crymes

Anti-Corruption and Governance Expert