Flashback Friday – Past ethikos Favorites: Exhale: Incentives

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ct-2014-12-degrootBy Shawn DeGroot
From ethikos, an SCCE publication.

It seems to be an appropriate time of year to discuss incentives that often are associated with rewards. As a noun, incentives are something that incites action or greater effort as a reward offered for an action. Many compliance incentives were developed as a result of the Federal Sentencing Guidelines; however, there are new compliance and ethics officers who may not be aware of or those that have chosen to ignore the following standard:

CHAPTER EIGHT

PART B – REMEDYING HARM FROM CRIMINAL CONDUCT, AND EFFECTIVE COMPLIANCE AND ETHICS PROGRAM

(6) The organization’s compliance and ethics program shall be promoted and enforced consistently throughout the organization through (A) appropriate incentives to perform in accordance with the compliance and ethics program; and (B) appropriate disciplinary measures for engaging in criminal conduct and for failing to take reasonable steps to prevent or detect criminal conduct.

The key word in the statement above is “shall” meaning, not optional. To initiate a plan, criteria should be developed to incentivize the workforce consistently. Without criteria there will more than likely be inconsistency and an employee who constantly calls with issues simply to receive the reward. Drawing a name at an employee meeting for a reward is an easy approach; however, it’s not as effective. Best practice would be to develop incentives for compliance reporting that result in change. A few examples are to reward an employee who submits a concern and/or issue that results in a policy revision, a change in a process, or leads to enhancing the compliance education.

The type of reward or incentive can be tangible or intangible, such as a designated parking spot for a month, four hours of vacation, free cafeteria meals for a week (although that may be taxable in the near future), coffee cards, gift certificates, cash, or items with your company’s logo. The issue and incentive could be generated and awarded to a department. If you have appropriate influence and supportive management, wouldn’t it be nice to collaborate with the director and provide an item staff have been requesting for their break room or an item on their budgeted wish list? Another approach with incentives is to work with the Marketing department (as applicable) to select logo jackets, portfolios, or caps to be distributed during Compliance and Ethics Week.

The last component with incentives is who decides whether the issue/concern submitted has value and resulted in change. The compliance team could decide or the compliance committee could make the decision. Selection by the multi-disciplinary compliance committee would promote inherent awareness simply through the act of reviewing the issue that was submitted with the associated change.

Regardless of the type of reward, developing criteria for incentives, implementing it, and executing a plan of action will benefit the organization, demonstrate effectiveness, and create awareness of the compliance program in a positive manner.