Leveraging Tone at the Top: Turning Intent Into Global Culture

Nearly every executive will tell you they are in favor of ethics and compliance. Ask a CEO whether they support a strong culture and the answer is almost always yes, along with an offer to help. The hard part is what comes next: actually building a program that leaders can participate in, deciding which leaders to enlist, and turning their standing in the organization into a durable culture of compliance that reaches every corner of the enterprise.

In this Ethicsverse session, titled Turning Intent Into Global Culture, host Nick Gallo, Co-CEO and Chief Servant at Ethico, was joined by moderator Matt Kelly, CEO and Editor of Radical Compliance; Tara Shewchuk, SVP, Chief Privacy, Integrity and Compliance Officer at Medtronic; and Kershwin Singh, a lawyer and compliance officer whose career spans ZOLL, Pfizer, and Boehringer. The conversation moved from defining what it means to leverage tone at the top, through the practical mechanics of winning buy-in and equipping middle managers, to how regulators view the whole effort. What follows are the key takeaways.

Key Takeaways

What Leveraging Tone at the Top Actually Means

Kershwin framed tone at the top as a framework describing how culture and ethics cascade through an organization. The executive team sets the formal rules, middle managers shape the daily climate, and frontline employees reflect it in their everyday conversations and behavior. Employees mirror leadership behavior, good or bad, and actions speak louder than policies.
Tara added the 30,000-foot view: ultimately this is about culture, and culture eats strategy for lunch. You want your most senior leaders, starting at the board and moving down through the C-suite and middle management, setting a tone of integrity. It is a say-do ratio, not just words, and it includes teaching leaders to be good listeners who create a climate where it is safe to raise concerns.
Nick offered an analogy: employees set their watch to a clock, and that clock is not only the CEO but their local leader. To leverage that means putting in a little effort for a lot of output. He noted that a once-a-year CEO video is fine, but the signals that carry real weight are the ones with a cost attached, like a leader describing a deal they walked away from because of an ethical issue.

Culture Is a Control, Not a Nice-to-Have

Tara pushed back on the idea that this is soft work. Everything an organization achieves runs through people, and no volume of policy substitutes for execution at the individual level. A key hallmark is speak-up culture: employees need to believe leaders value integrity and genuinely expect them to raise concerns and offer differing points of view, because that also drives innovation.
Culture functions as a core risk control from both a speak-up angle and an information angle, ensuring the right signals reach compliance so the organization does not fly with blind spots. A listener captured it well: culture is the foundation on which all other controls sit, and tactical controls become window dressing when no one has answered why they exist.
Kershwin agreed and stressed that leaders have to understand the why before you enlist them to do anything. Tying the ask back to culture, speak-up, risk mitigation, and innovation is what earns their engagement, and having an intentional plan with assigned tactics beats a set of one-off ideas.

The Cascade Runs Through Middle Managers

Tone at the top is not only senior management. Kershwin pointed to data showing employees listen to their direct managers more than anyone else at the company. At some large firms, frontline and junior employees do not even know the CEO's name, but they know the manager who controls their bonus, their raise, and their performance review.
Tara reinforced the point with a striking figure: roughly 60 percent of concerns are raised directly to an employee's own manager. Hitting the full spectrum of leadership, and making sure managers set the right tone and create an open environment, is therefore critical.
A listener summed up the through-line that the panel embraced: tone at the top is most effective when it becomes action at the middle and then trust at the frontline. Employees need to see both consistent messaging and visible follow-through.

Winning Buy-In and Making It Mandatory

Kershwin described a repeatable playbook. Start by getting buy-in from the most senior leader of a chosen division, business unit, or country, then decide which managers to train, because you cannot rely on business leaders to deliver the message the way you intend without support.
His rule was simple and non-arbitrary in effect: anyone with five or more direct reports delivers a tone-at-the-top presentation or scenario to their team. Making it mandatory changed the dynamic in a favorable way and let the team capture data. Managers were asked to tag the content onto an existing meeting rather than call a separate one, and crucially to present it as their own belief in doing the right thing rather than something compliance told them to do.
Attestation closed the loop: after delivering the material, managers confirmed they had done it and shared feedback. The key was making it as easy as possible, since departments differ. An R&D leader may welcome the chance for introverted staff to present twice a year, while a sales team inundated with training will resist anything that takes time away from selling, so you have to sell the program to managers too.

Engaging the Most Senior Leaders

Tara called it a Rubik's Cube: different tactics and individuals for different problems. At the top she has engaged the CEO and even a board member to deliver messages to the employee base, and at the middle she has run everything from hour-long ethics circles unpacking case studies like Boeing to five-minute stand-up conversations on the manufacturing floor.
Signature recognition works. Medtronic's annual integrity award, the Compass Award named after its code of conduct, is championed by the CEO, who celebrates the employees and their stories front and center, just as the company does for quality.
Sprinkling in fun helps. For Integrity Week, Tara and her CEO, both hockey fans, suited up in Medtronic jerseys and passed a puck to kick things off. She has also enlisted senior leaders to act in video vignettes dramatizing conflicts of interest or meals-and-hospitality dilemmas; the executives enjoy it, and employees get a kick out of seeing their general manager play a part at national sales meetings.

Overcoming Employee Cynicism

Nick acknowledged the familiar split into two camps: those who buy in and those who dismiss it as going through the motions. He assumes positive intent, describing cynics as ethical refugees whose early idealism was worn down by corporate reality, with the cynicism a hard shell over a softer core that still wants to believe the organization can be better.
You win those people over by making it real, and you make it real by talking about it constantly and matching words with actions. His parenting analogy landed the point: if you tell your kids to say please and thank you but do not say it to a server, the dissonance kills the message.
He pointed to Alcoa under Paul O'Neill, who after a worker's death made employee safety his central agenda item, opening investor meetings with a safety minute and refusing to blame workers. Over time the relentless, cost-bearing consistency pulled skeptics into believers and coincided with dramatic growth. Matt added the DuPont example, where leaders were expected to connect nearly every meeting back to the company's core values, and it was that permanence that convinced everyone the values were taken seriously.

Building Turnkey Tools for Managers

Kershwin's team gave managers a menu rather than a mandate on content. They built short 10-to-12-page presentations with speaker notes visible only to the presenter, so managers could deliver confidently and look knowledgeable, alongside one-page case studies that walked a group through two discussion questions and then revealed suggested answers.
The topics spanned conflicts of interest, reporting concerns, anti-bribery and anti-corruption, travel and entertainment, social media, and the use of AI, so a manager could pick what mattered most to their team. Each topic offered subtopics tailored by function, with distinct examples for manufacturing, sales, or procurement.
The design goal was to make participation low-burden and customizable. Managers chose the topic and the example, which increased ownership while keeping the compliance message consistent.

Sustaining Consistency Over Time

Tara stressed durability: tone at the top cannot be a one-time blast but a regular, methodical, consistent touchpoint across every level. Members of her team carry it as a goal and objective, driving it across the 30 businesses and 140 countries where Medtronic operates.
When engagement is not happening organically, her team brings the tools forward and offers real-time nudges, such as reminding a leader with an upcoming town hall to lead with a patient story that ties doing what is right back to the mission and to integrity.
Measurement anchors the effort. Medtronic uses an ethics score that rolls up company-wide and down to every leader with five or more employees. A score below expectation signals a disconnect the leader is expected to improve, with compliance's help, and Nick noted the power of a tangible number: leaders love data and respond to it far better than to a vague sense that something feels off.

Making Change Stick

Nick was candid that change is a struggle. Managers fall into the same two camps; some act immediately while others need constant reminders, which is exactly why relationships matter more than an email that gets filed and never read.
Absent a formal ethics score, you make it happen tactically by following up, asking how the two minutes went and what resonated, and simply refusing to let apathy or busyness win. Getting genuine CEO or division-leader buy-in provides wind in your sails to push process adherence downward.
Tara tied it back to the business: a high-integrity organization is ultimately a high-performing one, driving better innovation and engagement, so this should not be siloed as a separate ethics initiative. Nick cited an ECI finding that leaders who talk about integrity frequently earn roughly a 90 percent rate of employees wanting to emulate them, versus under 50 percent for those who rarely do, a strong correlate worth using to sell the effort.

The Regulator's Lens

Kershwin connected the work to the Justice Department's three fundamental questions: Is the compliance program well designed? Is it applied earnestly and in good faith? And does it work in practice? Prosecutors specifically examine how leaders, through their words and actions, encouraged or discouraged compliance, and what concrete actions demonstrated leadership on remediation.
A documented tone-at-the-top program, reinforcing the message at the top, in the middle, and as buzz at the bottom, becomes valuable if an investigation ever arises. It helps show the misconduct was a rogue actor rather than the company, shifting liability toward the individual wrongdoer, which Kershwin reminded the audience was always the goal.
He drew a sharp contrast in perspective: prosecutors always have the luxury of a known infraction, while the compliance team building the program cannot know what will go wrong someday. The job is to anticipate the efforts that would lead to a more favorable outcome, and engaging senior management consistently is one of the highest-impact bets available.

Talking About ROI

Tara said the effectiveness of tone-at-the-top work is absolutely worth measuring. The mandatory five-minute manufacturing-floor stand-ups produced measurable gains in speak-up culture, engagement, and inclusion, and fewer blind spots mean fewer quality issues, which is better for patients and the bottom line. She has also seen this evidence help immensely in front of prosecutors.
Nick reframed ROI as a persuasion mechanism, a handle for translating an initiative into terms a decision-maker understands. Because a metric is hard to quantify does not make the effort invalid; it just opens other persuasion paths, the same way one could ask what the ROI of Alcoa's safety focus turned out to be.
Kershwin shared a practical timing tip: pitch a tone-at-the-top initiative to leadership a few days after a meeting reviewing all the company's open investigations. When he did, the president smiled and asked how he could possibly say no.

Closing Thought

The throughline of the hour was that tone at the top is not a slogan or an annual video but a system: leaders who understand the why, a cascade that reaches the middle managers employees actually listen to, turnkey tools that make participation easy, and the consistency to keep it alive over years. As Nick put it in closing, you do not need to build an entire program to get the ball rolling, and the leverage available from this conversation is enormous. Pair genuine buy-in with measurement, relationships, and the discipline to follow through, and intent at the top becomes culture everywhere, the kind that protects employees, satisfies regulators, and makes the whole organization perform better.