Active listening and NOM-035: how to reduce psychosocial risk through leadership
When the NOM-035 questionnaire flags risk under "leadership and workplace relationships", the cause is rarely a manager who shouts. It is almost always a manager who does not listen: decides without asking, does not recognize effort and does not hear about conflicts until they blow up. Active listening is the cheapest control measure for that category, and here we explain how to apply it through managers and how to document it.

In this article
- What does active listening have to do with NOM-035?
- What the reference guide measures on leadership and relationships
- What a manager who does not listen looks like in the questionnaire results
- Five active listening practices for managers
- How to build active listening into the policy and the control measures
- How to know whether it worked
- Want to bring this to your team?
What does active listening have to do with NOM-035?
The standard measures, among other categories, "leadership and workplace relationships", and much of what the questionnaire detects there depends on whether managers listen: clarity when giving instructions, recognition, conflict handling and sense of belonging.
NOM-035-STPS-2018 is the Mexican standard on psychosocial risk factors in the workplace. According to the standard, the company must have a prevention policy and apply control measures; with more than 50 workers, it must also assess the organizational environment. A company can have the policy signed and, through the way its managers talk in 1:1s and meetings, generate the very risk the policy claims to prevent. The questionnaire picks it up even if nobody reported it.
What the reference guide measures on leadership and relationships
The "leadership and workplace relationships" category groups three domains: leadership, workplace relationships and violence. The reference guide for the organizational environment adds the "social support" domain, covering performance recognition and insufficient sense of belonging.
All four domains touch listening behaviors. Leadership: whether instructions are clear and whether the manager attends to questions and proposals. Workplace relationships: whether conflicts are addressed or ignored, whether there is collaboration. Violence: whether there is mockery, interruption or public put-downs. Social support: whether effort is recognized and whether the person feels their opinion counts. None of them is fixed with a poster; all of them change when the manager asks, stays quiet, paraphrases and follows up.
What a manager who does not listen looks like in the questionnaire results
The answers that raise risk in this category describe everyday manager behavior, not extraordinary events. The table links them to the domain that captures them and the listening practice that addresses them.
| Sign in the team | Domain that captures it | Listening practice that addresses it |
|---|---|---|
| "My manager decides without asking" | Leadership | Open questions to the team before deciding |
| "Nobody recognizes what I do" | Social support (recognition) | 1:1 closing with specific recognition of something the person said or did |
| "Conflicts are ignored until they blow up" | Workplace relationships | Biweekly screen-free 1:1 with a direct question about friction |
| "I get interrupted or mocked in meetings" | Violence | No-interruption rule and a reporter at the end of each meeting |
| "I do not feel part of the team" | Social support (belonging) | Paraphrasing and visible follow-up on what the person proposed |
Five active listening practices for managers
A biweekly screen-free 1:1, asking before deciding, paraphrasing the complaint before answering it, recognizing specifically and closing with "what do you need from me?". Five behaviors, each under five minutes, that cover the four domains.
- Biweekly 20-minute screen-free 1:1. Phone face down, laptop closed. The first question is not "how is the task going?" but "what is getting in your way?". The date and one agreement per meeting get logged.
- Ask before deciding. For any change that affects the team (schedules, workloads, customer allocation), the manager first asks "what do you see that I do not?" and summarizes what they heard before announcing the decision. They may decide the same thing; the team will know it was heard.
- Paraphrase the complaint before answering it. "If I understood correctly, the problem is that the extra load came without notice, not the load itself." No justifying in the first sentence. It is exercise one of the ten active listening exercises.
- Recognize specifically. "Thanks for the report" does not count. "The way you organized the report by customer saved us Thursday's meeting" does. Once a week per person, out loud or in writing.
- Close with "what do you need from me?". The last question of every 1:1 and every team meeting. The answer gets written down and the next meeting starts with it.
How to build active listening into the policy and the control measures
Active listening fits in the prevention policy as an explicit commitment by managers, and in the control measures as an action with an owner, a frequency and evidence: training with a DC-3 certificate, a 1:1 log and follow-up on agreements.
- In the policy: one line committing managers to listen to and follow up on staff concerns, with a channel and a frequency.
- As a control measure: active listening training for every manager, with an attendance list and a DC-3 certificate that serve as evidence.
- As a record: the 1:1 log (date, agreement, follow-up), one line per meeting. Without a record, the measure does not exist for the purposes of the standard.
- As follow-up: the NOM-035 software lets you compare the category across questionnaire rounds and locate the areas where a manager needs more support.
If your company is just starting, the full NOM-035 compliance service covers policy, questionnaires, measures and evidence; the NOM-035 course prepares HR and managers to sustain it.
How to know whether it worked
By comparing the "leadership and workplace relationships" category between two questionnaire rounds and, before that, with short signals that show within weeks: 1:1 attendance, agreements kept, complaints that reach the manager before they reach HR.
- Percentage of 1:1s held versus scheduled, per manager.
- 1:1 agreements closed by the next meeting.
- Conflicts the manager reports before they arrive as a complaint to HR.
- Voluntary turnover per area, compared with the previous semester.
In the active listening course managers practice the five behaviors on their real conversations and leave with the 1:1 log ready to use as evidence. When the diagnosis also points to how work is assigned, we combine it with the leadership course and the effective communication course.
Want to bring this to your team?
We train managers in active listening with a DC-3 certificate and leave them the 1:1 log and the agreement follow-up as evidence for the control measures. Message us on WhatsApp, fill out the contact form or open this site's live chat: we send a proposal with three scope options and a closed price in under 24 business hours, with the DC-3 certificate and Geedle Bot included. The full program is at the active listening course and the catalog at training courses for companies.


