Strengthening Your Program with Tone from the Middle – Live from the Washington D.C. Regional Compliance & Ethics Conference

30bdf28By Stephanie Gallagher, JD


Kristen Liston, CCEP
VP, Learning Content Strategy
SAI Global

Rachel Batykefer, CCEP
Associate Director, Compliance
Teva Pharmaceuticals

The Washington D.C. Regional Compliance & Ethics Conference is underway, and we have a full house of folks from the area here to learn, network, and earn their continuing education credits. The first session of the day is one that is very practical and relevant to compliance professionals all over the country, not just the D.C. area – Strengthening your program with Tone from the Middle.

The speakers, Kristen Liston and Rachel Batykefer, were dynamic and shared a lot of great information about this topic. They emphasized that compliance programs are evolving and keeping up with this necessary evolution requires a culture shift from relying solely on the “Tone at the Top” model of years past.

While the culture of “Tone at the Top” is still very relevant and important, the culture shift that needs to take place is one of “Tone at the Middle.” On this point, Kristen pointed out something very powerful, “If you’re not setting your tone at the middle, it’s a good bet that someone else is.”

Changing culture requires a different toolset and approach. Here are some practical considerations and best practices when making this culture shift in program and organization:

  • Be sure to collect continuous feedback and implement program improvements. This can be done by polling employees and checking in with surveys and focus groups.
  • Ensure that the total employee population receives relevant training through audience identification. It is important to identify online vs. offline employees and tailor the experience.
  • Develop supporting materials and programs for all employees. Utilize a “living” FAQ document and update it continuously. Consider developing a quick reference guide of compliance “help desk” to answer questions.
  • Launch your engagement efforts. Implement mobile app contest, marketing incentives, live training and roadshows, or a communication campaign. A great example that was brought up is to launch a poster making campaign. This is a great way to engage employees and recognize contributors to the program.
  • Finally, simplicity is key. The further throughout your organization you want a message to go, the simpler it needs to be. The easier you make it for someone to do something right, the more likely it is they will do it right.

If you’re thinking that revamping is an existing program is an intimidating endeavor, just keep in mind that one of the key takeaways from this session is to just get started. Your program doesn’t have to be perfect right out of the gate, as long as you have a foundation, you can continue to build and improve. A strong Tone at the Middle can extend the reach of your compliance program.

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