Compliance and Ethics Program
Stay Compliant
Our Compliance and Ethics (C&E) Program is designed to encourage ethical conduct and compliance with the law. Our C&E Program fulfills the elements of an effective compliance and ethics program as found in Chapter Eight of the U.S. Sentencing Guidelines Manual and endorsed within other guidance documents issued by the U.S. Department of Justice (DOJ) and the U.S. Department of Treasury's Office of Foreign Assets Control (OFAC), including but not limited to the Evaluation of Corporate Compliance Programs, the Resource Guide to the U.S. Foreign Corrupt Practices Act, the Department of Justice (DOJ) Criminal Division's Corporate Enforcement and Voluntary Self-Disclosure Policy, the Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations and the Framework for OFAC Compliance Commitments. Our C&E Program also incorporates best practices identified by other government agencies and international organizations, and we monitor new guidance from relevant sources as released.
The chief objectives of our C&E Program are to prevent unlawful and unethical conduct, detect such conduct should it occur and pursue prompt and appropriate remedial action when warranted, with the aims of promoting our strong compliance culture, protecting our valued corporate reputation and ensuring investor confidence. The DOJ and the Securities and Exchange Commission (SEC) have observed in their guidance documents that no compliance program can ever prevent all criminal activity. We acknowledge that reality, but we also assert in good faith that our C&E Program has been well designed, is effectively implemented and tested, and is enforced consistently in a corporate environment fully supportive of its objectives.
