Incentive Programs and Compliance
Incentives are integral to the compensation plans of a wide range of workers. CEOs, senior management, sales executives, and even rank-and-file employees may have them.
Many experts point to their value in rewarding behavior that is in the interest of the organization and for keeping workers focused on activities that help the bottom line.
At the same time, however, the incentives can pose great risks.Many corporate scandals have shown that workers and corporate leaders may give in to the temptation to cheat to make their numbers, doing whatever they can to achieve their goals and reap the rewards. As a consequence, incentive plans may turnout to be a roadmap for compliance risk.
This danger argues for the compliance department having a role in reviewing incentive plans, if nothing else than to develop controls that ensure the numbers are hit properly, without violating policies, procedures, the law, and ethical norms.
To better assess the role of the compliance team in reviewing incentive plans, in April 2017 the Society of Corporate Compliance and Ethics and the Health Care Compliance Association fielded a survey among compliance professionals.The results indicate that, despite the risks, compliance rarely plays a role in evaluating incentive programs.