In the DOJ’s 2023 ECCP, Incentives and Disciplinary Measures it stated:

Incentive System – Has the company considered the implications of its incentives and rewards on compliance? How does the company incentivize compliance and ethical behavior? Have there been specific examples of actions taken (e.g., promotions or awards denied) as a result of compliance and ethics considerations? Who determines the compensation, including bonuses, as well as discipline and promotion of compliance personnel?

In this podcast episode titled "Sales Incentives and Compliance," Tom Fox explores the risks and consequences of misaligned sales incentives. Using the Wells Fargo scandal as an example, Fox discusses how a flawed incentive program can lead to compliance failures. He emphasizes the importance of aligning incentives with compliance goals and highlights the role of human resources in implementing effective compliance programs. The podcast warns that sales incentive programs can become high risk or even illegal if not properly designed and monitored. It concludes by emphasizing the significance of HR's involvement in creating a more effective compliance program and its impact on overall organizational success.

Three key takeaways:

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

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