Next week the Society of Corporate Compliance and Ethics (SCCE) will hold its annual conference in Washington DC. It is one of the top national conferences in compliance and ethics around. Together with K&L Gates LLP partner Amy Sommers I will be speaking on the recent GlaskoSmithKline PLC (GSK) corruption enforcement action in China and its implication for the compliance practitioner. I hope that you are planning to attend and if you are going to be in attendance that you will drop by the session Amy and I are leading.
Last week I interviewed Roy Snell, SCCE Chief Executive Officer (CEO), for my FCPA Compliance and Ethics Report podcast, which can be found here or on iTunes. One of the things that we discussed was membership in the SCCE and some of the benefits that it brings. I believe one of the best items that the SCCE offer is the Complete Compliance and Ethics Manual (the Manual). This is a one volume compendium of all things that the compliance practitioner might need in his or her practice. It is updated quarterly with CD supplements mailed to you.
One of the questions that I am regularly asked is how a company can create incentives to do business in compliance with the Foreign Corrupt Practices Act (FCPA) juxtaposed with the discipline that the FCPA Guidance suggests that every effective compliance program should maintain. An article in the Manual, entitled “Ideas for Using Incentives in Compliance and Ethics Programs”, presents some of the SCCE’s best ideas related to incentives, evaluations and rewards for compliance programs, they are as follows:
At the end of the day, not only are incentives necessary in a program, but they also help a company put a more positive face on its compliance program. Compliance and ethics should not simply be about enforcing laws, rules and regulations. Recognition of employees in companies who do well and conduct business ethically is an important step and employees should be recognized for showing ethical leadership, this means not just rewarding those at the top but anyone in the organization. I hope that these suggestions from the SCCE Manual will help to generate some ideas of your own.
Visit the FCPA Compliance and Ethics Blog, hosted by Thomas Fox, for more commentary on FCPA compliance, indemnities and other forms of risk management for a worldwide energy practice, tax issues faced by multi-national US companies, insurance coverage issues and protection of trade secrets.
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© Thomas R. Fox, 2013
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