An employee incentive program that provides effective disciplinary measures for compliance missteps and incentives for positive behavior is one of the “hallmarks of an effective compliance program,” according the DOJ/SEC FCPA Resource Guide.  To assist companies in creating such a program and determining the optimal positive and negative incentives, the Anti-Corruption Report is publishing a best-practices guide to developing and implementing an incentive program that works.  This, the second article in the series, discusses the carrots and sticks a company can use to encourage compliant behavior.  The first article in the series discussed the risks and benefits of incentivizing compliance, outlined three steps a company should take before creating an incentive program, and discussed how a company should measure compliance.  See also “When, Why and How Should Companies Discipline Employees for FCPA Violations?” (Sep. 19, 2012).