Tag: compliance incentives

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Compliance Tip of the Day

Compliance Tip of the Day: Clawbacks

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements.

Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game.

Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law.

Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

In today’s episode,  we discuss the role of clawbacks in both a comp system and a compliance regime.

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

To check out The Compliance Handbook, 5th edition, click here.

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Compliance Tip of the Day

Compliance Tip of the Day: Sales Incentives and Compliance

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements.

Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game.

Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law.

Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

In today’s episode, what is the role of sales incentives in your compliance program?

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

To check out The Compliance Handbook, 5th edition, click here.

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Compliance Tip of the Day

Compliance Tip of the Day: Executive Compensation and Compliance Incentives

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements.

Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game.

Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law.

Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

In today’s episode, what is the role of executive compensation in compliance incentives?

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

To check out The Compliance Handbook, 5th edition, click here.

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Compliance Tip of the Day

Compliance Tip of the Day: Designing Compensation to Operationalize Compliance

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements.

Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game.

Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law.

Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

In today’s episode, we consider how to design your compensation program to operationalize your compliance regime?

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

To check out The Compliance Handbook, 5th edition, click here.

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Compliance Tip of the Day

Compliance Tip of the Day: 6 Core Principles for Compliance Incentives

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements.

Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game.

Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law.

Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

In today’s episode, we ask what are the Six Core Principles for Compliance Incentives?

 

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

To check out The Compliance Handbook, 5th edition, click here.

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Compliance Tip of the Day

Compliance Tip of the Day: Incentivizing Compliance

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements.

Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game.

Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law.

Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

In today’s episode, we discuss how, since at least 2004, the DOJ and SEC have advocated for incentivizing doing business ethically and in compliance.

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

To check out The Compliance Handbook, 5th edition, click here.

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program: Day 17 – Promotions to Operationalize Compliance

Welcome back as we dive into the role of HR in compliance and ethics. Today, we will explore the significant role of HR in operationalizing compliance within organizations. Join us as we uncover practical advice and data-driven insights on how HR can promote ethical behavior and create effective internal controls. According to the Department of Justice, promotions demonstrate a company’s commitment to compliance and ethics. By using advertisements to reinforce these values, organizations can showcase their dedication to fostering a culture of integrity and accountability.

The role of HR in corporate compliance programs should be more recognized. Suppose your company has a culture where compliance is perceived to compete or, worse yet, antithetical to HR. In that case, the company must hit all cylinders and may be moving towards dysfunction. Another way you can operationalize compliance is through HR’s involvement in employee promotion. Such compliance embedded into the promotion process can also be considered an internal compliance control. By doing so, your compliance may work to create an effective internal controls regime as mandated by the FCPA and other anti-corruption laws.

Three key takeaways:

  1. Denying a promotion or award due to an employee’s ethical lapses.
  2. Use promotions to reinforce your company’s commitment to compliance and ethics.
  3. Should you wait for great?

For more information, check out The Compliance Handbook, 4th edition here.

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31 Days to More Effective Compliance Programs

One Month to More Effective HR in Compliance: Day 5 – Role of HR in Incentivizing Compliance

Welcome to the August edition of One Month to a More Effective Compliance Program. In the month of August, 2023 we will consider the role of Human Resources in a best practices compliance program.

In this episode, Tom Fox explores the role of HR in implementing effective compliance programs within companies. The episode focuses on the importance of incentivizing compliance and ethical behavior through both financial and non-financial incentives. The Department of Justice’s guidance emphasizes the need for positive incentives, such as personal evaluations, promotions, and rewards for ethics and compliance leadership. The podcast discusses various avenues for implementing incentives, including cash bonuses and non-compensation rewards like t-shirts or ethical awards. It emphasizes the role of HR in driving the right behavior through incentive structures and warns against solely promoting based on financial targets. Overall, the podcast highlights the significance of HR in creating a fully operationalized compliance program that fosters an ethical work environment.

 Three key takeaways:

  1. The DOJ 2023 ECCP specifically calls out incentives for doing business ethically and in compliance.
  2. HR can lead the efforts around incentives.
  3. Incentives go beyond financial rewards.

For more information, check out The Compliance Handbook, 4th edition, available on LexisNexis.com.

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Corruption, Crime and Compliance

How to Build a Compliance Compensation System

The DOJ is advocating for increased consequences for individuals who engage in misconduct or fail to exercise proper oversight, via the implementation of compliance compensation programs that include financial penalties. Companies need to develop incentives and penalties in a balanced manner to maintain ethical performance, while ensuring the potential for accountability. A crucial aspect of enforcing these policies is the execution of robust clawback provisions as part of the executive’s contract and bonus terms. These clawbacks can act as a deterrent for misconduct, and their enforceability largely depends on the clarity of their language, among other things. In this episode of Corruption, Crime and Compliance, Michael Volkov explores compliance compensation systems and their role in corporate governance in detail. 

You’ll hear Michael talk about:

  • Clawback provisions are important rules that determine how executives’ contracts and bonus terms can be enforced. Companies have a responsibility to execute robust clawback provisions to ensure accountability and deter misconduct.
  • Compliance programs are becoming increasingly vital to global companies as they grapple with complex legal and economic risks. These programs are crucial in reinforcing compliant behavior and promoting positive corporate citizenship.
  • The DOJ has emphasized the importance of compensation systems and consequence management in corporate compliance programs. Not being proactive in reviewing these systems is considered a serious mistake that requires urgent attention and correction.
  • DOJ’s focus has expanded towards consequence management, seeking to escalate penalties for those involved in misconduct. Companies are required to implement compliance compensation programs focusing primarily on clawbacks.
  • Clawback policies, often limited to senior executives and specific conduct, need to be broadened in their scope and applicability. Notably, the Dodd-Frank Act mandates listed companies to have a written clawback policy for financial restatements resulting from accounting misconduct.
  • Compliance rewards act as a significant incentive for ethical behavior and compliance. Executives and managers who fulfill specific compliance requirements may become eligible for performance-related rewards.
  • Compliance compensation systems must be designed to hold individuals accountable for misconduct. Penalties, including retroactive discipline and financial penalties like clawbacks or deferred compensation systems, can be potent deterrents.
  • A comprehensive compliance compensation system requires careful crafting to minimize litigation and defense possibilities. It involves identifying the executives and managers to be included in the penalty system and determining the corresponding percentage penalties.
  • A company must balance its incentive structure, considering factors like large contingent payouts to executives and ethical performance requirements. Clarity in written policies and employment agreements fortify clawback provisions.
  • Collaboration between business, finance, legal, and HR is pivotal in the design and implementation of effective compliance reward and penalty systems.

 

KEY QUOTES:

“The DOJ wants to add to their risk calculation, and that’s requiring companies to implement compliance compensation programs that include financial penalties against those actors who engage in misconduct, or supervisors that fail to rein in their underlings or conduct proper oversight to ensure compliance.” – Michael Volkov

 

“Companies have to isolate and weigh incentives and bonus structures to make sure that they can still target accountability penalties commensurate with the risk posed by the executive if he or she engages in misconduct.”  – Michael Volkov

 

“The key determinant of clawback enforceability is whether the company has insisted on execution of robust clawback provisions as part of the executive’s contract and bonus terms.” – Michael Volkov

 

Resources:

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

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Compliance Into the Weeds

Compliance into the Weeds: Compliance and Middle Managers

The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, going into the weeds to explore a subject more fully and looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds!

Join Tom and Matt as they delve into middle managers’ crucial role in fostering a culture of ethics and compliance within organizations. In this episode, the hosts discuss compliance officers’ challenges in working with middle managers and share some practical tips on building alliances, teaching soft skills, and developing personal relationships. They also examine the use of incentives and consequence management in promoting compliance and highlight the need for positive incentives for middle managers. Take advantage of this insightful and thought-provoking discussion on enforcing internal controls in a compliance program and learn more about the different ways to ensure compliance in gift travel and entertainment expenses. Tune in now to stay ahead in the world of compliance!

Key Highlights:

  • The Role of Middle Managers in Compliance
  • Training Middle Managers on Ethical Leadership
  • Investing in middle managers for ethical conduct
  • Compliance: Incentives and Consequence Management

 Notable Quotes:

“Compliance officers need to think about because you live and die in the success of your corporate culture, and the middle managers are the custodians of that culture.”

“Compliance officers should think about how do I help middle managers. How do I coach them on how to be good leaders?”

“Nothing is as significant as that personal touch point.”

“If the middle manager either turned a blind eye to the unethical practice or should have known about it but was just so aimless about it and didn’t care, should that middle manager suffer consequences along with the frontline employees who committed the offense? And the answer was generally yes.”

 Resources

Matt 

LinkedIn

Blog Post in Radical Compliance

Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn