Speak Up, Not Out: How to Build Compliance Programs Employees Actually Trust

Everyone talks about “tone at the top.” But what matters just as much—if not more—is “mood in the middle.”

Keith Thomas emphasized that frontline managers and mid-level leaders shape how employees feel about speaking up more than any memo from the C-suite. FedEx has invested in middle management training that focuses on emotional intelligence, listening skills, and the idea that more reports are a sign of organizational health, not dysfunction.

In short: it’s not enough for executives to set the tone. Managers have to walk the talk.

FedEx saw a significant boost in alert line usage after updating their speak up posters. Why? Because the old poster featured a scowling employee and felt intimidating. The new materials showed real employees, smiling, in uniform, reflecting the local culture and region. They also included human language: “We care about your concern.”

Sometimes small visual cues are loud cultural signals. As Will Richards reminded us, language like “whistleblower” can trigger very different reactions around the world. What sounds principled in one region may sound like betrayal in another. That’s why he suggests localizing language and choosing terms like “speak up,” “report concerns,” or “raise your voice”—phrases that meet people where they are.

Retaliation isn’t always dramatic. Sometimes it’s subtle social isolation, silence, or being left out of meetings. Will emphasized that companies need to communicate how they prevent retaliation—not just say they do.

Keith shared how he speaks directly with reporters and implicated parties, sets expectations, and invites reporters to contact him personally if anything feels off. This approach, rooted in empathy and transparency, fosters trust even when outcomes are difficult.

Even anonymous communications through case management systems can carry warmth. A thoughtful closing note that thanks the reporter, reiterates confidentiality, and explains why details can’t be shared goes a long way.

A high number of reports doesn’t automatically mean success. Nor does a low number mean trust. Instead, both Keith and Will emphasized using multiple forms of data to understand culture:

• Integrity surveys (ideally every 1–2 years)
• Follow-up surveys post-report
• Focus groups, especially in global or hard-to-reach regions
• Analyzing anonymity rates, manager engagement, and case types

Keith noted that FedEx slices its survey data by country and job level to spot trends and tailor messaging. Will added that local roles (like drivers or front-line staff) often hold insights others miss, and organizations should actively include them in feedback loops.

• Audit your messaging. Does it sound human? Inclusive? Localized?
• Talk to your managers. Are they equipped to receive concerns empathetically?
• Follow up. Close the loop with reporters—even when you can’t share details.
• Gather better feedback. Start small with pulse checks if surveys feel too big.

Ultimately, building a speak up culture isn’t about perfection. It’s about progress, trust, and never losing sight of the human being on the other side of the report.

Want to hear the full conversation?
Watch the full webinar recording here.

Stay tuned for the next session in the EQS Summer Series: Compliance That Clicks: Rethinking Employee Engagement.