As a football fan, I was pleased with the National Football League’s (NFL) harsh disciplinary response to the New Orleans Saints’ practice of providing financial incentives for inflicting injuries on opposing players. According to the NFL, the team’s head coach deserved the one-year suspension because the cash incentive violated an express rule against such noncontractual payments and, significantly, he obstructed the NFL’s investigation. The NFL’s commissioner said this clear “tone at the top” was designed to punish but also deter future compliance malfunctions.
This episode, however, offers a stark example of how a dysfunctional “tone at the middle” can undermine an organization’s compliance program. The NFL sets the compliance mandates, and the teams are expected to implement the processes and measures necessary to comply. In the case of the New Orleans Saints, the middle management (the general manager and coach) failed to echo the league’s tone, and the compliance calamity ensued.