The message employees believe is the decision they see

The speech is only the beginning

Imagine an executive saying that integrity comes first. The next day, a manager tells the team that a missed target is unacceptable, whatever the circumstances. Employees now have two messages and must decide which one describes the organisation they actually work in.

Ethical leadership becomes visible in choices about time, money, promotion and accountability. A leader who asks for a compliance review and then protects the team’s time to complete it sends a different signal from one who requests the review while insisting that nothing can delay delivery. The distinction is operational, not rhetorical.

Tone at the top establishes expectations. The tune at the middle is how managers translate those expectations into assignments, conversations and reactions. The metaphor is useful because inconsistency can emerge without an explicit instruction to break a rule.

Make the difficult choice discussable

A manager needs more than a slide describing corporate values. They need language for the moment an employee brings an inconvenient concern: what to ask, what not to promise and where to take the matter. Rehearsing that conversation is a practical leadership exercise.

A useful opening is to thank the person for raising the issue, clarify the immediate risk and explain the next step. Avoid asking the employee to prove the entire case before anyone will listen. Equally, avoid promising an outcome before the facts have been considered. Protect confidentiality appropriately and keep the person informed within legitimate limits.

Leaders should also explain decisions where commercial interests were constrained. The purpose is not to publicise sensitive cases. It is to show, through suitable examples, what organisational commitments mean when they carry a cost.

Examine the management system around the manager

Telling managers to behave ethically will accomplish little if staffing, incentives and deadlines repeatedly make compliance impractical. Review the environment alongside individual conduct. Do targets encourage rushed approvals? Are employees penalised for raising a legitimate delay? Can a manager obtain advice without losing the authority to manage?

In its September 2024 evaluation guidance, the US Department of Justice considers both senior and middle management commitment. This supports examining the layers between board statements and frontline experience; it does not prescribe a single leadership model.

Our recommendation is to select a few recurring management decisions and agree what good practice looks like. Include how exceptions are documented, when advice is requested and how a concern is followed up. Make these expectations part of management conversations, rather than a separate annual declaration.

Reference: DOJ evaluation guidance (September 2024).

Assess consistency without creating a popularity contest

A culture survey can help identify patterns, but a favourable score does not prove ethical leadership. Employees may like a manager who avoids difficult conversations. Others may rate a manager poorly because the manager fairly challenged a risky practice. Interpretation matters.

Look for patterns across interviews, escalation records and decisions about performance. Ask whether people can describe a recent occasion when a concern was handled well. Examine whether different teams face different consequences for similar conduct, and whether those differences have a defensible explanation.

Share findings at a level that supports action without exposing individuals unnecessarily. A useful outcome is a specific management improvement: clearer escalation, a revised target, a better response to concerns or more consistent treatment of exceptions. Leadership development should produce changes that employees can recognise.

Put it into practice

1. Ask managers to rehearse a response to an inconvenient concern.
2. Review one target for unintended pressure to bypass a control.
3. Compare how similar exceptions are treated across two teams.
4. Include a concrete integrity decision in the next leadership discussion.