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Seventy percent of compliance professionals have experienced retaliation, according to a Case IQ survey presented by Shannon Walker, executive vice president at Case IQ, during Ethisphere’s “The Price of Integrity” webcast. The people paid to prevent retaliation can’t protect themselves from it. CEOs were the retaliator more than a third of the time, and CEOs and direct managers together accounted for more than half. No wonder “tone at the top” has turned into something people hear in a keynote and stop believing by the time they’re back at their desks. Walker put it bluntly: tone at the top is often something leadership says rather than something it does.
“Tone at the top” shows up in nearly every program description, RFP response, or conference panel as shorthand for ethical leadership, and everyone nods. Ask someone to define it in observable terms, though, and almost nobody can. Most leaders treat it as something you do once: a memo, a town hall mention, a value printed on a slide.
Employees watch for tone at the top as a pattern of behavior: what gets rewarded, what gets tolerated, whose calendar clears for an uncomfortable conversation and whose doesn’t. That pattern either survives the trip down through the layers of management between the C-suite and the floor, or it thins out.
What Employees Watch For
Employees treat what they can observe as evidence, and they believe what they see over what they’re told. That includes what leaders don’t do: the conversations skipped, the concerns left unanswered, the outcomes never explained. Absence reads as loudly as action.
Take access. When someone in compliance asks for 15 minutes with a senior leader to flag a conduct concern, what happens to that request becomes the signal. A leader who takes the meeting in person that week demonstrates something no values statement can. A leader who hands it off to a deputy, reschedules it twice, or waits until the problem has escalated demonstrates the opposite: ethics is easy to invoke in a keynote but not a priority once it’s competing for a slot on the calendar.
Promotions work the same way. When a manager who hits every number while sitting on three flagged concerns from their own team still advances on schedule, the promotion becomes the lesson, whatever the Code of Conduct says. Employees notice who moves up, who gets quietly managed out, and who gets a pass.
Silence teaches, too. A program that discloses nothing about typical case timelines or the range of discipline it uses leaves employees to draw their own conclusions, and confidentiality rarely requires that much silence. Leadership chose not to say, and employees treat that choice as an answer.
No one ever announces these lapses. They accumulate one unremarked decision at a time, until employees reach a verdict that decides whether the next person with a concern speaks up or stays quiet.
Where the Pattern Thins Out
The gap between what leadership says and what it does plays out in every layer of the organization.
Part of the problem is that neither end can see the other. The C-suite can’t observe how a line manager treats their team day to day, so nothing catches the pattern thinning out in real time. It surfaces later, through a survey or a complaint, by which point it has taken hold. The same blindness runs in the other direction. Frontline employees see the C-suite mostly through organization-wide emails and scheduled appearances, but also through the stories that travel by word of mouth: who earns a promotion, who receives discipline, what happens to the person who raises a concern.
Picture a manager whose team suddenly has an open investigation. They’ve almost certainly had training (which has probably gone stale by now), and they’ll follow it as long as it matches what they’ve seen happen to past complaints. When training and policy say one thing and experience says another, experience usually wins, and the problem festers. If they’ve watched concerns get swept aside without consequence, or the people doing the sweeping get rewarded, that’s the lesson that sticks. A policy is only as strong as people’s evidence that it’s enforced.
Managers sit between both ends, ideally positioned to carry information in either direction. But they can’t pass along what they don’t know. Employees are far more likely to bring an ethical concern to their manager than through any other reporting mechanism, but if those same managers aren’t specifically trained to receive and pass along ethical matters brought to them, then it doesn’t much matter what message the C-Suite sends.
That brings it back to the top, where leaders often have no training to go stale. Ethics and compliance training usually concentrates on managers and stops short of senior leaders. Senior leaders need the same periodic training as everyone else, covering how to promote ethical leadership, how to take critical feedback well, and how to hold a difficult conversation instead of shutting it down. Neither a C-suite title nor a board seat comes with those skills installed.
Concerns traveling upward hit a different obstacle. Leaders who retaliate punish the person who raised the concern, and that teaches everyone who hears about it to stay quiet next time. Walker described a bottleneck: an employee already hesitant to come forward reaches a compliance officer who is just as hesitant to escalate it. The concern gets quieter at every step because the cost of raising it climbs each time someone new has to decide whether to risk it.
By the time all of that has played out, employees are holding two versions of leadership: the one leaders describe and the one they see for themselves. They believe the second.
Closing the Gap Where Employees Can See It
Better communication alone doesn’t fix any of this. Closing the gap takes specific commitments leadership can be seen keeping.
Start with access. A standing slot is harder to hand off or reschedule than a request. Ethisphere’s 2026 World’s Most Ethical Companies® data shows that 68% of Honorees hold a standing executive session with the oversight committee, and another 26% say the session is available but not regularly scheduled. Erica Salmon Byrne, Ethisphere’s Chief Strategy Officer, has called the second arrangement worse than having none, since a special request tells the room something is already wrong. Ethics and compliance leaders can push for the standing version, then tell employees it exists.
The same principle applies to training. Push for executives and the board to complete the same regular ethics training as everyone else, and make it visible rather than private. It should cover how to receive a concern without retaliating against the person who raised it. A dated, recurring requirement shows employees that nobody is too senior for it.
Managers also filter what travels upward, and some filtering is healthy. Senior leaders can’t and shouldn’t hear about every local problem, and solving them close to home is much of a manager’s job. The filter becomes a blockade when employees feel they have nowhere to go but their manager. So advertise every available channel, and set the expectation that a manager who hears an ethics concern passes it to ethics and compliance within a set window. Tell employees about the window, too. An employee who hears nothing back in that window knows it’s time to use another door. Then publish aggregate figures, such as complaint categories, time to close, and how many investigations led to corrective action, to fill the silence with information without naming anyone.
It doesn’t take a saint, only leaders willing to put specific commitments on a visible schedule, so employees can compare what’s said with what’s done instead of guessing. That’s the difference between tone at the top as a statement and tone at the top as a pattern that survives the trip down to the floor. Tone at the top is whatever employees can verify; everything else is just a speech.
For the program-level view, see Ethisphere’s earlier look at the topic, Tone at the Top: Advancing Ethics & Compliance.
Author Bio
Emily Schnurr | Culture Analyst, Ethisphere, Guest Contributor
Emily Schnurr is a Culture Analyst on Ethisphere’s Data & Services team, contributing to culture assessment projects that help organizations measure and improve their ethical culture. She supports client engagements by analyzing survey data and translating findings into actionable insights.
