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Ask an Expert


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Alexandra Wrage
President and Founder, TRACE


Nicola Bonucci.jpg
Nicola Bonucci 
International Lawyer and former
Director for Legal Affairs OECD
Dave Lee.jpg
Dave Lee
FCPA Compliance Consultant, TRACE
Sunny McCall.jpg
Sunny McCall
Senior Director II, Compliance Training, TRACE
Lee Nelson.jpg
Lee Nelson
Independent Compliance and
Ethics Attorney
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Jessica Tillipman
Associate Dean for Government Procurement Law, The GW University Law School
  • Writer's pictureLee Nelson

Middle Management: A Compliance Force Multiplier

Staff meeting

No compliance team can be everything everywhere all at once. An effective compliance program is truly an organization-wide effort. As a compliance officer, ensuring that your internal stakeholders know what to do is fundamental – as in, it is fun to meet colleagues in person to help them develop a compliance mentality and best practices.

A key compliance force multiplier is mid-level management. These unsung heroes often are reliable compliance partners especially when gently reminded that it is career enhancing to be an ethical manager who cares about protecting the organization. Now that you have their attention, offer coaching on ways they can use their ethical voice to provide that important ‘tone from the middle’. Here are a few suggested points to consider raising: 

  1. Know where to find policies online, especially those relevant to the team’s work, and remind employees about them. 

  2. Be aware of all touchpoints with government officials or entities in any country and ensure employees follow the approval process. 

  3. Request employees to complete their online training and policy acknowledgement(s) before the deadline. Make it part of your performance criteria.  

  4. Direct an employee who raises a potential or actual conflict of interest to the relevant system or internal team.  Remember that your consideration and approval as the manager may be needed.   

  5. Apply a trust-but-verify approach to employee expense reports and procurement requests by taking time to check them, including the receipts. 

  6. Contact Compliance or HR immediately if you become aware of possible fraud or employee misconduct. Do not investigate allegations on your own. 

  7. Set the example by complying with policies, and always treating everyone and organization assets with respect. 

In conducting these conversations, be mindful of body language – it can say a lot. And importantly, listen for concerns the manager raises even if outside of your talking points. Follow up on those with a sense of urgency. More work, yes, but consider it a compliment that the manager feels it’s safe to confide in you. 

Finally, be sure to send a follow-up email to say thanks, reiterate your key points, provide links to policies, etc., and, as always, your contact information. 

Presto, you have just increased the power and reach of your compliance program.

Independent Compliance and Ethics Attorney

1 comentário

10 de abr.

simple but really effective guidance! thank you Lee!



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