Oe forms such as personnel evaluations and promotions, rewards for improving and developing a company’s compliance pro- hapter 5 gram, and rewards for ethics and compliance leadership.” Guiding Principles Some organizations, for example, have made adherence to of Enforcement compliance a significant metric for management's bonuses so that compliance becomes an integral part of management’s everyday concern. Beyond financial incentives, some compa- transactions. Risk-based due diligence is particularly impor- nies have highlighted compliance within their organizations tant with third parties and will also be considered by DOJ by recognizing compliance professionals and internal audit and SEC in assessing the effectiveness of a company’s com- staff. Others have made working in the company’s compli- pliance program. ance organization a way to advance an employee’s career. Although the degree of appropriate due diligence SEC, for instance, has encouraged companies to embrace may vary based on industry, country, size and nature of the methods to incentivize ethical and lawful behavior: transaction, and historical relationship with the third-party, some guiding principles always apply. [Ad]ake snmeppity, ethics and compliance pant of tlhe First, as part of risk-based due diligence, companies promotion, compensation and evaluation processes as well. For at the end of the day, the most effective should understand the qualifications and associations of way to communicate that “doing the right thing” is a its third-party partners, including its business reputation, i ne fe Comes ana ee and relationship, if any, with foreign officials. The degree of and career advancement, all that counts is short-term scrutiny should increase as red flags surface. profitability, and that cutting ethical comers is an ac- Second, companies should have an understanding of cepableway ef getting thers, theyll yertommvorthar the business rationale for including the third party in the measure. To ci