The Manager in the Middle

Between policy and practice, there is always a person.

Compliance programmes are typically designed from two ends. At the top, they receive visible commitment from senior leadership — the tone from the top that every governance framework rightly identifies as essential. At the front line, they reach employees through training, communication, and the systems designed to make reporting possible.

Somewhere in the middle, often without specific acknowledgment or support, sits the manager.

Not the executive whose public endorsement of compliance values signals strategic commitment. Not the individual contributor whose job is to follow the rules. The person responsible for a team — who translates the organisation's stated values into daily practice through every conversation, every decision, every response to a situation that neither the code of conduct nor the training module fully anticipated.

Pressure from both directions, support from neither.

The manager in the middle occupies a structurally difficult position. From above, they receive strategic direction, commercial targets, and the expectation that they will translate both into team performance. From below, they receive questions, concerns, dilemmas, and occasionally escalations — situations that require judgment about things the policy manual does not cover.

In practice, this means that a middle manager is simultaneously responsible for achieving results and for creating the conditions in which those results can be pursued ethically. These obligations usually coexist without difficulty. But when they come into tension — as they periodically will — the manager faces a genuine dilemma with real consequences on both sides.

A manager who prioritises results at the expense of integrity does not necessarily do so because they are unconcerned with integrity. They may have received no preparation for the moment when the two are in tension. They may have absorbed, through observation, a culture in which commercial performance is explicitly rewarded and ethical conduct is implicitly expected but never recognised. They may simply be alone with a difficult decision, with no mechanism to escalate and no colleague to consult.

Role-specific preparation for the decisions that matter.

Supporting the manager in the middle does not require a separate programme. It requires that the existing programme recognise their specific situation and build what they actually need into its design.

It requires training that addresses the decisions managers face — not generic anti-bribery scenarios, but the real dilemmas of managing a team under commercial pressure. How do you respond when a high-performing team member describes a shortcut that produces results but raises questions? How do you handle a situation where escalating a concern will create friction with your own manager? How do you maintain a culture of integrity in a team when the organisation around you does not always model what it preaches?

It requires that the speak-up architecture specifically includes managers — that they have a way to raise concerns upward without it being interpreted as an admission of failure. A compliance programme that makes it easy for individual contributors to report concerns but leaves managers without a parallel mechanism has missed something important.

It requires that compliance communication address managers directly — not as the delivery vehicle for messages aimed at their teams, but as people who have specific questions, specific pressures, and specific needs.

Compliance culture lives in the decisions that managers make when nobody senior is watching and no procedure covers the situation exactly. Building those managers is not a supplement to the compliance programme. It is, in many organisations, the most important part of it.