A. Financial Incentives for Compliance
1. Simplicity
Keep the compensation plan simple and even employee KISS, keep it simple sir, when designing your program.
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A. Financial Incentives for Compliance
1. Simplicity
Keep the compensation plan simple and even employee KISS, keep it simple sir, when designing your program.
2. Alignment
As the CCO or compliance practitioner, you need to posit the most important compliance goal your entity needs to achieve. From there you should determine how your compensation program can be aligned with that goal.
3. Immediacy
Finally, under immediacy, it is important that such structures be put in place “immediately” but in a way that incentives employees. As a part of immediacy, there must be sufficient communication with your employee. In the world of employee compensation incentives, there should be transparency as to the expectations.
What about the inter-connectedness of senior management compensation in a compliance program. This was by Gretchen Morgenson, former columnist of the New York Times, in a piece entitled “Ways to Put the Boss’s Skin In the Game”, which dealt with a long-standing question about how to make senior executives more responsible for corporate malfeasance?
B. The Fair Process Doctrine
In the Department of Justice’s Evaluation of Corporate Compliance Programs, Prong 8 Incentive and Disciplinary Measures it states: Incentive System – Consistent Application – Have the disciplinary actions and incentives been fairly and consistently applied across the organization?
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