Compliance Week's Carnival study

Another valuable insight from Compliance Week’s in-depth study of Carnival and its approach to compliance and ethics relates to the use of incentives. Sadly, there continues to be a sense among some in the compliance field that incentives are somehow too difficult or exotic to tackle. Some don’t even understand that incentives play an indispensable role in the compliance and ethics field. Yet Carnival’s chief compliance officer, Peter Anderson, has charged through this mythology and taken concrete steps.  

In my experience, anything is impossible if you don’t even try. But as I spelled out in the white paper I did for SCCE there are many ways to address incentives in a compliance program, as long as you will do something more than sit on your hands. See Murphy, “Using Incentives in Your Compliance and Ethics Program” (SCCE; 2012), https://assets.hcca-info.org/Portals/0/PDFs/Resources/library/814_0_IncentivesCEProgram-Murphy.pdf    

Anderson provides good examples in describing Carnival’s approach. He suggests that to measure a company’s culture one should ask questions like these:

·      What is the company incentivizing?

·      How does the company reward positive behavior?

The Compliance Week study’s author, Aly McDevitt, notes Carnival’s view that it is necessary “to build in performance measurements. The company must be clear about what it’s expecting from its employees by being explicit about how it will incentivize positive behavior and disincentivize improper conduct.”

Another example of incentives comes from the environmental area. Anderson says, for example, that once a month every ship identifies employees exceeding expectations on compliance and protecting the environment. They are rewarded with cash prizes and have their photographs taken and posted on notice boards. In another example, when the company learns of someone quickly intervening to stop pollution, that individual receives an elegant silver coin. The company also recognizes “environmentally excellent ships” and provides trophies for these.

By offering these types of practical examples, Compliance Week is providing us a useful service in offering these in-depth studies.