Guide to Creating an Effective Compliance-Based Employee Incentive Program (Part Two of Two)

An employee incentive program that provides effective disciplinary measures for compliance missteps and incentives for positive behavior is one of the “hallmarks of an effective compliance program,” according the DOJ/SEC FCPA Resource Guide.  To assist companies in creating such a program and determining the optimal positive and negative incentives, the Anti-Corruption Report is publishing a best-practices guide to developing and implementing an incentive program that works.  This, the second article in the series, discusses the carrots and sticks a company can use to encourage compliant behavior.  The first article in the series discussed the risks and benefits of incentivizing compliance, outlined three steps a company should take before creating an incentive program, and discussed how a company should measure compliance.  See also “When, Why and How Should Companies Discipline Employees for FCPA Violations?” (Sep. 19, 2012). 

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