Our Ethics and Compliance program consists of ten core elements that collectively enable the Company to raise awareness and prevent mistakes and breaches of our CoBE, detect those mistakes and breaches when they do happen, and respond and remediate quickly when needed.
These ten elements are based on the expressed expectations of national regulators such as the U.S. Securities and Exchange Commission (SEC), the U.S. Department of Justice (DOJ),1 the U.K. Serious Fraud Office (SFO) and others, as well as good practices endorsed by public international organizations such as the OECD, Transparency International and the World Bank.
Accelerating our efforts within Ethics and Compliance
In recent years, we have made significant investments to strengthen our Ethics and Compliance program with policies, processes and tools for preventing, detecting, reporting and remediating non-compliance. The improved program is the work of our internal teams working alongside external experts.
We have focused much of our efforts over the past years on the following four areas:
- Leadership and culture
- Third party engagements
- Compliance and investigation capabilities
- Internal controls
- Leadership and culture
- Policies and procedures
- Compliance organization
- Risk assessment
- Training and communications
- Reward and sanctioning
- Third-Party management
- Allegations and investigations
- Monitoring and testing
- M&A Due diligence and integration
1 In particular, they reflect guidance issued by the DOJ and SEC included in “A Resource Guide to the U.S. Foreign Corrupt Practices Act” (2012).
