I think we can all agree: compliance professionals are obsessed with culture. And for good reason. A strong culture sets the tone for ethical decision-making, fosters trust, and protects an organization from the risks that come with misconduct.
But here’s the uncomfortable truth: culture isn’t a monolith. It’s a patchwork of behaviors, leadership styles, and unspoken norms. And if you’re not careful, one bad apple can spoil the entire bushel.
The power of microcultures
When we talk about culture, we often think about it in broad strokes—our values, our mission, our company-wide training programs. But in reality, culture is local. It’s what happens in the day-to-day interactions between employees and their managers. It’s shaped by who gets promoted, who gets a pass, and who gets ignored.
This is why microcultures matter. A single department, team, or even a small group of employees can form their own ecosystem within a company. If that microculture aligns with the organization’s broader values, great. But if it doesn’t? That’s where the trouble starts.
The bad apple effect
We’ve all seen or heard about it before. A high-performing but toxic manager. A leader who prioritizes results over ethics. A small group of employees who bend the rules “just a little.” When left unchecked, these microcultures create an environment where people feel pressure to conform, even when it contradicts the organization’s values. And if employees see bad behavior tolerated in one area of the company, they start to question whether the company’s ethics really apply across the board.
It’s not just an internal issue—these microcultures can spill over into regulatory risk, reputational damage, and legal consequences. The cost of ignoring a problem like this is almost always higher than addressing it head-on.
Spotting the warning signs
So how do you know if a toxic microculture is forming? Here are a few red flags:
- High turnover in a specific department – If people are leaving a particular team at a much higher rate, ask why.
- Inconsistent survey results – If engagement or ethics survey scores vary wildly between teams, it’s worth digging deeper.
- Whisper networks – If employees feel safer sharing concerns informally rather than through official channels, there’s a trust issue.
- Managers who block transparency – If a leader is resistant to oversight or reacts defensively to compliance inquiries, take note.
Fixing the rot before it spreads
The good news? Just as culture isn’t built overnight, it’s also not beyond repair. Here’s how to address bad apples before they ruin the bushel:
- Don’t just set expectations—reinforce them. Make sure employees know that ethical behavior isn’t optional, no matter how high someone’s performance metrics are.
- Look beyond the org chart. Culture is often shaped by informal leaders—long-tenured employees, influencers within teams, and middle managers. Know who they are.
- Hold leaders accountable. If a microculture is toxic, leadership needs to step in. That might mean removing a problematic manager or restructuring a team.
- Give employees safe ways to speak up. Ensure reporting channels are accessible, trusted, and free from retaliation.
Don’t design your compliance program around the bad apples
One of the biggest mistakes compliance professionals can make is designing programs around the worst actors. It’s tempting to build policies, training, and oversight mechanisms to prevent the bad apples from causing harm—but doing so risks alienating the vast majority of employees who want to do the right thing.
Instead, compliance programs should be designed to support and empower ethical behavior, making it easy for the right actions to become second nature. Strong cultures don’t thrive on fear or excessive controls; they thrive on trust, accountability, and clarity.
The bottom line
A strong culture doesn’t happen by accident. It takes vigilance, accountability, and the willingness to address tough issues head-on. Compliance professionals have a unique role in shaping the culture of an organization—not just by setting policies, but by identifying and addressing the small pockets of dysfunction before they become full-blown risks.
Because at the end of the day, the difference between a culture that thrives and one that falters isn’t just about what’s written in the Code of Conduct. It’s about what’s tolerated in the break room, the conference call, and the one-on-one meeting. And that’s where real compliance work happens.
