Whether it is cybersecurity, privacy or any other type of regulatory compliance, the much-talked-about “tone at the top” is often cited as crucial for an effective compliance program.  See “Establishing Strong Cybersecurity and Data Privacy Leadership: The Roles of the Chief Information Security Officer and Chief Privacy Officer (Part One of Two)” (May 6, 2015); Part Two (May 20, 2015).  Ensuring that tone is conveyed throughout the organization, however, is equally important.  Getting the compliance message across typically falls on an organization’s middle managers.  A recent Society of Corporate Compliance & Ethics program featuring Charlotte Nafziger, director of compliance of T-System, Inc., explored the importance of middle management in developing an effective ethics and compliance program and the ways compliance officers can engage middle management in doing so.