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The ‘frozen middle’ can make or break a compliance program

Denise Lee Yohn is a go-to expert on brand-building for national media outlets. She’s also a popular speaker and consultant, and an influential writer.

I talked to her about her 2018 bestseller, Fusion: How Integrating Brand and Culture Powers the World’s Greatest Companies.

Q: Hi Denise, I really enjoyed reading “Fusion.” There are a number of compliance lessons here. But first, why did you write it?

I’ve always believed that brand-building starts inside, meaning that if you want to build a strong, valuable brand, you must start by cultivating a strong brand-led culture inside your organization. I wrote about this principle in the first chapter of my first book What Great Brands Do and I head from many folks who wanted to learn more about it.

Also, there seems to be a culture crisis in the business world today. Many companies struggle with issues of diversity, equality, and sexual harassment while fighting a fierce war for talent — and so many employees are not engaged at work. But I found few resources that explained how to cultivate a healthy, effective, sustainable culture, so I wanted to crack the code on culture-building the same way I had done on brand-building with my first book.

And based on my experience and the research I’ve conducted, I’ve found that the most successful organizations are the ones that align and integrate their external brand identities and internal workplace cultures – so that led me specifically to write about brand-culture fusion.

Q: Where do you see the greatest gaps between brand values and corporate culture?

Most of the time employees just don’t know what the purpose and values of the organization are, or they don’t see how they apply to them personally and their work. People in leadership positions in the organization need to connect those dots. They need to help each person understand why the purpose and values are important and to see how they help the organization pursue its purpose and live out its values.

Q: What’s the best way to spark a conversation where the organization realizes the value of fusing internal culture and external branding?

The escalating war for talent and the need to unify and align increasing diverse and dispersed workforces are two salient reasons to pursue brand-culture fusion. The need to pass customers’ test of brand authenticity is another. Achieving greater workforce alignment and increasing your differentiation also make strong cases for aligning and integrating brand and culture.

Alternatively, you can talk about the dangerous disconnects that can arise when brand and culture are mismatched, such as those that were revealed at Wells Fargo and Uber. Also, your culture-building efforts are likely to go to waste when your brand and culture are not aligned and integrated. You might end up with happy, productive employees who produce the wrong results.

Q. Is there a “behavioral road map” when it comes to creating culture?

Organizations that have the most success with values alignment and implementation are those that 1., ensure they have clear, focused, and differentiated values; and 2., clearly define them and link them to expected behaviors and standards.

At Argentinian bank Banco Supervielle, Patricio Supervielle, chairman, CEO, and president, knew it was not enough to state his company’s core values as “agile,” “simple,” and “friendly” — especially if he wanted to turn such common notions in the banking industry into a differentiating competitive advantage. So he and his colleagues engaged in a one and a half year road show to meet with all their managers and executives and flesh out what the core values meant.

As a result, they were able to define the behaviors they expected employees to demonstrate for each value. For “simple,” they specified “make decisions as close as possible to the customer” and for “friendly,” they spelled out “respect the agreements reached.” They also defined those behaviors they would not accept. For “agile,” they spelled out that “setting unchallenging goals” and “ignoring mistakes and not learning from them” is unacceptable.

Q: What do you mean by the danger of the “frozen middle?”
Leaders in the middle layers of an organization’s hierarchy, like department managers, store managers, and program leaders, wield the most influence on an employee’s daily experience and therefore are a critical group in any culture transformation effort. But middle managers in many organizations are not engaged to the degree that higher-level leaders are.

Some of the problem is inherent in their roles. Most often middle managers are burdened with day-to-day operations that make it challenging for them to focus on tasks that may seem longer-term or less defined. But also top organizational leaders often take the engagement of these middle managers for granted or they view them as employees they need to influence rather than understanding that they must also be deployed as the powerful influencers of other employees. If this management layer isn’t engaged, empowered, and equipped to cultivate the desired culture as much as are their higher-level counterparts, efforts to align and integrate brand and culture are likely to stall.

Thank you, Denise, I think that’s a good departure point for further reading, and I’ll look forward to continuing to follow your work!


Richard Bistrong is a contributing editor of the FCPA Blog and CEO of Front-Line Anti-Bribery LLCIn 2010 he pleaded guilty to a conspiracy to violate the FCPA and served fourteen and a half months at a U.S. federal prison camp. He was named to Compliance Week’s list of Top Minds in 2017 and was one of Ethisphere’s 100 Most Influential in Business Ethics in 2015. He was named by Thomson Reuters in 2018 as a Top 50 Social Influencer in Risk, Compliance and RegTech.

His award winning compliance training video, Behind the Bribe, produced in cooperation with Mastercard, was released in 2017. To request a demo of the full eleven-minute video or a licensing fee schedule, please click here.

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