Posts Tagged ‘executive compensation’
Compliance and Incentives, Part II
Today I want to return to the idea of effective incentives for corporate compliance. In a post on the subject last week, we explored some fundamentals of how to build an incentives program, but struggled with exactly how to tie executive compensation to compliance criteria. So for help, I turned to that fount of all…
Read MorePodcast: Compensation Clawback Strategies
Today we have another Radical Compliance podcast, this time to talk about compensation clawback policies: how to structure them, the challenges in using them, and what one recent FCPA case tells us about the favorable outcomes your company can achieve when clawbacks are part of your compliance program. The case in question involves Boston Consulting…
Read MoreCompensation & Misconduct: Two Examples
Everyone is buzzing these days about the Justice Department’s new ambitions to include executive compensation plans and disciplinary policies as part of effective corporate compliance programs, so today let’s review two recent enforcement actions that department officials have cited as examples: Danske Bank and Safran. Both cases were resolved in December. Danske Bank pleaded guilty…
Read MoreDeep Dive Into DOJ Compliance Guidance
Last week the Justice Department released new guidance on effective corporate compliance programs, to incorporate the department’s new stance on compensation clawbacks and disciplinary procedures that it wants companies to embrace. Let’s take a close read of those changes to see what’s going on. The updated guidance comes after numerous speeches by Justice Department officials…
Read MoreMore on Clawbacks, Message Apps
We have more details today on the Justice Department’s new policies for compensation clawbacks, and how prosecutors will expect companies to govern employees’ use of “ephemeral messaging apps” as part of compliance settlements. The news came from assistant attorney general Kenneth Polite, who spoke today at a white-collar crime conference in Miami. His remarks filled…
Read MoreMajor Clawback Policy From DOJ
The Justice Department dropped several news bombs today likely to have a profound effect on corporate compliance programs, including new credits for companies that pursue clawbacks against misbehaving executives and an expansion of the department’s National Security Division to crack down on sanctions violations. Deputy attorney general Lisa Monaco unveiled the plans in a speech…
Read MoreOn Boards, Disclosures, and Corporate Ethics
The Securities and Exchange Commission dropped a subtle hint this week about its latest expectations for corporate boards and what they disclose to investors. Corporate governance professionals might want to take a look, since I suspect we’ll be hearing more on this issue in the future. The case involves McDonalds and its former CEO, Stephen…
Read MoreHere Come the Clawback Clauses
The Securities and Exchange Commission enacted a rule today that will require public companies to adopt and disclose executive compensation clawback policies, echoing the Justice Department’s effort to make companies exercise clawbacks more often when their executives commit misconduct. The rule directs U.S. stock exchanges to update their listing standards so that listed companies are…
Read MoreStudy: Deferred Comp Boosts Ethics
We have a fresh bit of ethics and compliance academic research to start our week: a study from Australia demonstrating that deferred compensation is indeed a good way to curb misconduct risk among employees — and can even boost employee productivity, too. The study comes from Elizabeth Sheedy, business professor at Macquarie University and director…
Read MoreCalculating the Pay Ratio Rule
A new study shows that CEOs still make gobs more money than the rest of us mere mortals, although Corporate America uses a variety of approaches to demonstrate that point. ClearBridge Compensation Group analyzed 100 companies in the S&P 500 to see how they complied with the CEO Pay Ratio Disclosure Rule. That’s the requirement…
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