To me, in my eyes, yes, because without those steps.... If you're trying to change a culture, it's not an easy thing to do. You mention that you need to have the managers and the people at the top on board. That's definitely true. But you need to have ways to reach the people who aren't at the top. Having policies and training are ways that.... If they know that they can get in trouble or be reprimanded for something, they're more likely to think twice.
On May 28th, 2013. See this statement in context.