Discipline and Incentives

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APPENDIX 3-AA: Ideas for Using Incentives in Compliance and Ethics Programs

These are ideas from the Health Care Compliance Association and Society of Corporate Compliance and Ethics Academies’ classes on Building Incentives in Your Compliance & Ethics Program. The classes were divided into 4 teams, with each team asked to develop its best ideas related to incentives, evaluations and rewards. The other teams then judged each presentation.

Some editing has been added, including changing industry-specific references so that they apply more generally. It is hoped that this list will inspire more ideas from readers. While listing these does not mean we endorse them all, any particular idea might inspire the reader to develop an approach that will be perfect for his or her own circumstances.

Departments would nominate people who exemplify the integrity program; a board level committee would select the best and give the winner free, preferential parking for a year.
Provide as a reward a pin or other visible emblem. When the employee accumulates enough points, they can turn in the emblem for gifts or time off.
Rewards could include two season basketball tickets or free lunch passes.
Have a “dinner with the CEO” as recognition.
Have the annual compliance and ethics award winner flown in to the shareholders’ annual meeting with the award presented there.
Audit findings should include positive findings regarding compliance & ethics activities; these could be shared in a newsletter.
The compliance committee could select the department or work group that best exemplifies compliance & ethics. Measures could include such things as completing training on time, code of conduct attestations done on time, best personnel evaluations, etc. The reward could be a lunch for the department.
Those managers with the best compliance & ethics records could be awarded free tuition and expenses to attend a compliance academy and/or to get certified in compliance & ethics.
Make compliance & ethics certification (CHC, CCEP) a condition for promotion to senior management positions .
Reward employees for making recommendations and suggestions to improve the compliance & ethics program. This also brings in new, creative ideas.
Provide rewards and recognition for those who conduct self-audits and share the findings and lessons learned.
Require a compliance comprehension test as an adjunct to regular annual evaluations. A 100 percent score would be an added 1 percent pay increase on top of the usual incentives. 80 percent = .8, 70 percent = .7, less would equal zero.
Provide an incentive for reports to the helpline or otherwise to the compliance and ethics office that help avoid noncompliance or identify actual problems that are system errors. This would only be for reports about systems, but not about people, to avoid a bounty-hunter environment.
Make attendance at compliance training a condition for being in any responsible position.
Award organization-wide recognition if the compliance & ethics program overall gets a high score, e.g., time off for all employees.
Provide an incentive for all division and unit compliance and ethics officers to get training and certification (CHC, CCEP).
Performance indicators could be linked to a compliance plan. This could include timely submissions of required regulatory filings, on-time completion of compliance training, etc.
Provide on-the-spot recognition by peers/supervisors with certificates (“compliance bucks”) for behavior promoting compliance and ethics that can be redeemed for company merchandise.
Give $50 for any submissions to the company newsletter relating to compliance and ethics that are published.
Have a compliance and ethics courage award, e.g., for turning down a choice vacation trip from a vendor.
Have a system for compliance & ethics points or “president’s points” in small incremental amounts awarded based on performance during the month, quarter or year. The points would be totaled for each time period, with recognition for those receiving a certain number of reward points.
Senior leaders ask employees compliance and ethics questions on the spot; those who answer correctly get free movie tickets.
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