PR4.4 COMPENSATE & REWARD WORKFORCE
Align compensation plans and other incentives with program objectives and avoid inducing the workforce to step outside mandated and voluntary boundaries.


Management should define and use incentives as a means to prevent improper conduct, especially conduct that may occur beyond the "reach" of established controls. A full analysis should include consideration of both direct and indirect compensation such as fringe benefits and discretionary incentives that feed back into the direct and indirect compensation (e.g., providing large discretionary budgets that may have an impact on the employee's compensation).  For example, a sales representative may have discretionary funds to spend, and while not part of the direct compensation, the allocation of these funds has a correlation to his or her compensation.
Standards & Guidance
    PR4.4.S01
  • Promote and enforce program through appropriate incentives to perform in accordance with the compliance and ethics program
Core Practices
    PR4.4.101
  • Analyze compensation plans for jobs/roles that relate to revenue generation or financial roles/responsibilities, confirming that they do not induce illegal or unethical behavior
    PR4.4.102
  • Analyze for key roles including roles with substantial authority
Additional Practices
    PR4.4.201
  • Analyze compensation plans for all jobs/roles, confirming that they do not induce illegal or unethical behavior
    PR4.4.202
  • Analyze discretionary budgets or allowances for all jobs/roles, confirming that they do not induce illegal or unethical behavior
    PR4.4.203
  • Develop awards and other incentives to reward model conduct and leadership
GUIDELINE DETAILS
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