The FCPA Guide states that, “In addition to evaluating the design and implementation of a compliance program throughout an organization, enforcement of that program is fundamental to its effectiveness. A compliance program should apply from the board room to the supply room—no one should be beyond its reach. DOJ and SEC will thus consider whether, when enforcing a compliance program, a company has appropriate and clear disciplinary procedures, whether those procedures are applied reliably and promptly, and whether they are commensurate with the violation. Many companies have found that publicizing disciplinary actions internally, where appropriate under local law, can have an important deterrent effect, demonstrating that unethical and unlawful actions have swift and sure consequences.”
This means you need to have recognized incentives for doing business under your Code of Conduct and in fulfillment of your compliance policy and procedures. Incentives can be immediate (such as cash bonuses or other awards) or more long term (such as promotion within an organization). Yet, recent research has suggested that such things as a good word or two for an ethical job well-done can also go a long way toward incentivizing not only similar ethical behavior, but compliance as well.
