BELA Asks: How Do I Factor Compliance into Performance Evaluations?

Last March, the Department of Justice issued its updated Evaluation of Corporate Compliance Programs document, which aims to assist prosecutors in making informed decisions as to whether, and to what extent, a company’s compliance program was effective at the time when it committed some kind of punishable offence. We all know that crime doesn’t pay, but it helps if your company makes sure of it by incorporating compliance best practices into how it rewards its top performers. performance evaluations. To that end, Erica Salmon Byrne, Executive Chair of the Business Ethics Leadership Alliance, answers the burning question: How do I factor compliance into performance evaluations?
1:08 How do I factor compliance into performance evaluations?
2:51 Linking compliance to executive compensation
5:33 Uneven language from the DOJ
8:24 The effectiveness of clawbacks
10:55 Considerations for the 2024 proxy season
Full text of the March 2023 update to the Evaluation of Corporate Compliance Programs: justice.gov/criminal/criminal-fraud/compliance