Should ethics and Compliance be incentivized with rewards similar to sales commissions?
Providing tangible incentives to behave ethically and prioritize Compliance can make a big difference, according to panelists discussing the Foreign Corrupt Practices Act and the challenge of creating a healthy culture of Compliance.
Panelists at an event sponsored by the Practicing Law Institute in New York noted that companies can make their Compliance culture look great on paper, but the realities are often far less healthy. Compliance officers with experience in classic ‘checkbox compliance’ programs will no doubt relate to the limitations of that approach.
A big lever, according to panelists, is incentivizing ethical behavior and Compliance in the same ways that sales successes are incentivized. Seeing that your firm’s leadership makes tangible commitments–not just lip service–to strong ethics helps build a culture where employees know that playing by the rules is a central expectation of the job.
Defining the metrics for ethical behavior are often difficult, however. One panelist noted that an oft-used measure is whether employees attend trainings about ethics. But a check mark for attendance is usually a weak indicator of whether the ethics addressed in training sessions will gain deep traction.
In addition to tangible incentives, panelists suggested that company leaders make certain that rich and regular conversations about ethics, Compliance, and company culture occur.
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