In reality, “tone-at-the-top” is not really just “tone-at-the top” it is a lot more. I will try to be clear. Most people think that tone at the top is satisfied once the CEO puts out a statement of commitment to compliance. That is far from what I mean.
The real definition of tone at the top is — a commitment and repeated commitment from corporate leadership throughout the company to emphasize the importance to the company of compliance and ethical conduct, which is embraced and integrated into every level of business operations. That is a real mouthful but there is a lot more definition of terms needed to fill this out.
‘Enforcement 40’ for 2020
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