One of the ways to operationalize compliance and to drive it into the DNA of an organization is through a performance review. Indeed, the 2012 FCPA Guidance states, “DOJ and SEC recognize that positive incentives can also drive compliant behavior. These incentives can take many forms such as personnel evaluations and promotions, rewards for improving and developing a company’s compliance pro¬gram, and rewards for ethics and compliance leadership. Some organizations, for example, have made adherence to compliance a significant metric See more +

One of the ways to operationalize compliance and to drive it into the DNA of an organization is through a performance review. Indeed, the 2012 FCPA Guidance states, “DOJ and SEC recognize that positive incentives can also drive compliant behavior. These incentives can take many forms such as personnel evaluations and promotions, rewards for improving and developing a company’s compliance pro¬gram, and rewards for ethics and compliance leadership. Some organizations, for example, have made adherence to compliance a significant metric for management’s bonuses so that compliance becomes an integral part of management’s everyday concern.” See less -