During an internal audit, the compliance department discovers that a senior procurement manager responsible for international contracts has repeatedly ignored deadlines to complete mandatory anti-bribery training. According to the FSGO, which action should the organization take?

The organization should apply appropriate, documented disciplinary action in accordance with established company policies. Under the Federal Sentencing Guidelines for Organizations (FSGO), an effective compliance program must be promoted and enforced consistently throughout the organization. This requires the application of appropriate disciplinary measures for individuals who fail to comply with policies, including mandatory training requirements. When a high-risk employee like a senior procurement manager responsible for international contracts fails to complete critical anti-bribery training, the compliance department must apply the organization's progressive discipline policy. Documenting this action is vital to prove to regulators that the compliance program has real authority and is not a mere 'paper program.'

The incentive bonus or additional paid time off approach is incorrect because offering incentives or rewards for compliance with basic mandatory policies creates a moral hazard and signals to other employees that rules are optional unless incentivized. The immediate termination without formal review or inquiry approach is incorrect because immediate termination without due process or a formal inquiry is administratively reckless and can expose the company to wrongful termination or labor lawsuits; discipline should follow the established progressive policy. The no-action approach, which treats training as voluntary and allows revenue generation to outweigh compliance policy, is incorrect because ignoring compliance violations for top performers destroys the program's credibility and exposes the company to increased liability under the FSGO, which states that no individual is above compliance requirements.