I have long been a proponent of making employees bonuses subject to a deduction if the employee is found not to have complied with company policies. I haven’t had a lot of luck securing executive buy-in.
Now one company (whose reputation has suffered some dings for compliance issues of late) is doing precisely that. Hip, Hip, Hooray!
“Barclays Advisers’ New Performance Metric: Their Behavior,” Wall Street Journal, February 13, 2014 C1 http://on.wsj.com/1g35QH4. Apparently, the new policy has caused some of the employees to look somewhere else for a job. Sounds like the policy is working. I don’t understand why this isn’t a separate factor in the Federal Sentencing Guidelines Manual. How could a company be serious about compliance with law or policy if it didn’t have such a deduction? Recruiters in the field say that “they don’t expect other brokerages to follow suit.” What does that say about the cultures at those brokerages? Or their commitment to compliance?