In the 1949 movie Twelve O’Clock High, Gregory Peck, who plays a military officer, drives straight onto a secure military base without being stopped. The sentry never checks his ID, and as a result, blatantly violates security protocol.
Rather than letting this mishap slide, Peck stops the car and chews the young soldier out for violating the rules. Having witnessed this laxity within the organization, Peck then whips his unit into shape the way only a military general can.
While set in the context of an air force unit during WWII, the movie is really about the importance of leadership at the top. What does a movie about WWII have to do with compliance? For one thing, it illustrates what leadership at the top should look like when it comes to enforcing ethics and regulations.
It’s also one of the favorite movies of Jon Stentz, VP and Chief Counsel of International Development and Brands at HMSHost corporation, and a panelist at Compliance Week, where he shared some expert insights, including the movie reference, on tone from the top.
Stentz reinforces the idea that leadership should not only be the enforcer, but also the role model.
While you don’t have to be a drill sergeant to enforce tone from the top, leadership should provide a clear example to their employees about what constitutes ethical behavior. And about what’s acceptable at different companies in different industries.
Here are two practical ways the experts at the panel on Creating a Risk-Based Compliance Program recommend for companies who want to promote and attain a culture of compliance:
1 – Build a Strong Compliance Committee
In order to enforce tone from the top, Stentz mentions, companies must have a strong compliance committee with the right people on it.
“You need people who are empowered. People who are respected. People who can direct that things be done and make sure there are consequences for people who violate rules. And you have to make sure they have funding,” Stentz states.
2 – Have “Compliance Moments”
The second panelist, Heidi Rudolph, Managing Director at Morae Global highlights what she considers to be a shining example from one of her clients.
The client, a manufacturer who operates in high-risk companies, has what they call a “compliance moments” program.
What’s a compliance moments program? Well, each month, in any meeting with six or more employees, managers leading the meeting must go through three slides concerning something to do with compliance.
While it might sound like a novel idea to outsiders, to the company’s employees, these moments are just another day in the life.
Everybody knows that’s how they begin their meetings, Rudolph mentions. It’s a cultural institution, enforced by the people at the top and embraced by the employees. It’s just a habit built into the routine.
During the panel, Rudolph mentioned:
“Everyone here is afraid to use the buzzword of “tone at the top,” but it really does start with that. If leadership isn’t actively demonstrating it, then the metrics and risk assessment – or any element of compliance we’re talking about – will be doomed to failure if we don’t have that.”
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