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Internal Controls and Tone at the Top

What is the “Tone at the Top”?

“Tone at the Top” is a term that is used to define management’s leadership and commitment towards openness, honesty, integrity, and ethical behavior. It is the most important component of the control environment. The tone at the top is set by all levels of management and has a trickle-down effect on all employees of the University. If the tone set by management upholds honesty, integrity and ethics, employees are more likely to uphold those same values.

Lead By Example:

Setting the proper tone starts with managers at all levels leading by example and with integrity. Leaders should demonstrate through their own actions their commitment to honesty, ethical strength, reliability, and fairness. Management cannot act without these qualities and expect others in the University to behave differently.

Communicating and Promoting Ethics and Values:

Management must clearly communicate its ethics and values throughout the area they manage. These values could be communicated formally through written codes of conduct and policies, staff meetings, memos, etc or informally during day to day operations.


Another step management must take is to create a path for employees who are witnessing unethical behavior to be able to report such behavior. Employees are responsible to report such activity to management and should feel safe from retaliation. Managers should make their employees aware of the University Compliance Office and the Reporting Hotline.

Reward Integrity:

Management within the University should recognize employees who demonstrate honesty and integrity. Doing so will help communicate management’s commitment to this behavior and will encourage others to act in the same fashion. This will promote integrity within the University and have a positive influence on others.