The importance of tone and their role in internal controls
The writer

The importance of tone and their role in internal controls

In any organization, maintaining a strong ethical culture and effective internal controls is essential for success. 


Two critical elements that shape this culture are the Tone at the Top and the Tone at the Middle. 

Understanding their importance and how they relate to internal controls can help organizations create a trustworthy and compliant environment.

What is Tone at the Top?

Tone at the Top refers to the ethical climate set by an organization’s senior leaders, including executives and the board of directors. 

These leaders shape the organization’s values, mission, and overall direction. 

When senior management consistently demonstrates ethical behavior and integrity, it sets a powerful example for the entire organization.

What is tone at the middle?

Tone at the Middle is the ethical environment maintained by middle managers. These managers are the bridge between senior leadership and frontline employees. 

They are responsible for implementing the strategic vision and ethical standards set by senior management into everyday operations, ensuring compliance, and providing valuable feedback from the ground up.

Why tone at the top matters

Setting the Standard: Senior leaders define what behavior is acceptable and what is not. When they act with integrity, it signals to everyone in the organization that ethical behavior is a priority.

Building Trust: Employees look to senior leaders for guidance. When they see leaders acting ethically, it builds trust and encourages employees to follow suit.

Policy and Direction: Senior leaders establish policies and strategic directions that guide the organization. These policies form the foundation for the organization’s internal controls.

Why Tone at the Middle is Crucial

Operations: Middle managers bring the senior leaders' vision and policies to life. They ensure that day-to-day operations align with the organization’s values and ethical standards.

Compliance: Middle managers ensure that their teams comply with organizational policies and external regulations. They monitor adherence to ethical standards and take corrective actions when necessary.

Feedback: Middle managers are in close contact with employees and can provide valuable feedback to senior leaders about what is working and what needs improvement. This feedback loop helps refine policies and internal controls.

How they relate to internal controls

Internal controls are processes and procedures designed to ensure the integrity of financial and operational activities within an organization. 

Both Tone at the Top and Tone at the Middle play vital roles in the effectiveness of these controls.

Risk Management: Senior leaders identify key risks and establish policies to mitigate them. Middle managers implement these policies and monitor compliance at the operational level.

Accountability: A strong Tone at the Top holds everyone accountable, from the boardroom to the front line. Middle managers reinforce this by ensuring their teams adhere to established controls and report any discrepancies.

Consistency and Integrity: Consistent ethical behavior across all levels of management ensures that internal controls are applied uniformly. This reduces the risk of fraud and errors, maintaining the integrity of the organization’s operations.

Practical example

Imagine a company where senior leaders prioritize honesty and transparency. They implement a policy requiring detailed documentation for all financial transactions. 


Middle managers, understanding the importance of this policy, ensure their teams follow the documentation process. They regularly review the records and provide feedback to senior leaders about any challenges faced during implementation. 

This ongoing dialogue helps refine the controls and ensures they are effective and practical.


Both the Tone at the Top and the Tone at the Middle are essential for maintaining a strong ethical culture and effective internal controls. 

Senior leaders set the standard and direction, while middle managers bring these standards to life through operations, compliance, and feedback. By working together, they create a trustworthy, compliant, and efficient organization. 


Remember, ethical behavior and robust internal controls start at the top and resonate through the middle, reaching every part of the organization.

The writer is an independent Internal Audit Advisor, Enterprise Risk Management Consultant, and professional trainer. 

He is the founder and Chief Operating Officer of Redric Consulting, your trusted partner for comprehensive training and consulting services in the fields of Governance, Risk, and Compliance (GRC). 

With a proven record of accomplishment in Internal Audit, Internal Control, Compliance, Fraud Risk Management, and Cybersecurity, Redric Consulting empowers your organization and ensures its success.


You may reach out to Frederick on [email protected]

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