One of the ways to operationalize compliance and to drive it into the DNA of an organization is through a performance review. Indeed, the 2023 ECCP stated:

Incentive System…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?

Most HR experts will opine that properly executed performance appraisals are crucial to organizational productivity as well as the development of employee skills and employee morale. Moreover, they can serve a couple of different functions for a best practices compliance program. First, and foremost, they communicate to each employee their job performance from a compliance perspective.

Tom emphasizes the vital role of human resources in incorporating compliance into performance reviews and appraisals, ensuring it becomes ingrained in an organization's DNA. He discusses the need for concrete examples of actions taken as a result of compliance considerations to demonstrate the seriousness of compliance. Fox provides practical tips for conducting effective compliance employee appraisals, including giving constructive feedback and addressing compliance shortcomings. The episodes stress the continuous nature of performance appraisals and their impact on compensation and incentives within a compliance program. By conducting multiple appraisals throughout the year, compliance can be embedded into the company culture and compliance failures can be promptly addressed.

Three key takeaways:

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

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