Fcpa Compliance Report

The Evaluation of Corporate Compliance Programs, Prong 6, Incentives and Disciplinary Measures states:  Incentive System – How has the company incentivized compliance and ethical behavior? How has the company considered the potential negative compliance implications of its incentives and rewards? Have there been specific examples of actions taken (e.g., promotions or awards denied) as a result of compliance and ethics considerations? How can you measure compliance in senior management or evaluate it for the purposes of a bonus calculation? This issue has often been difficult to sustain in a company because the compliance evaluation of whether a senior manager or company leader is often viewed as too subjective. An article entitled, “Integrating Your Compliance Programme Into the Variable Compensation of Executives, addressed these issues and concerns.  The article was built around a case study of the Sorin Group, a healthcare multinational, and the company’s incentive program for its compliance regime. The co