ST0473DOJDOJ

ST0473

Accountability – What disciplinary actions did the company take in response to the misconduct and were they timely? Were managers held accountable for misconduct that occurred under their supervision? Did the company consider disciplinary actions for failures in supervision? What is the company’s…

Plain-language summary

What it actually means.

to be determined

Plain-language summary forthcoming. Source text below.

Source text

As written.

Accountability – What disciplinary actions did the company take in response to the misconduct and were they timely? Were managers held accountable for misconduct that occurred under their supervision? Did the company consider disciplinary actions for failures in supervision? What is the company’s record (e.g., number and types of disciplinary actions) on employee discipline relating to the types of conduct at issue? Has the company ever terminated or otherwise disciplined anyone (reduced or eliminated bonuses, issued a warning letter, etc.) for the type of misconduct at issue?

Assessed by HEXDI

What HEXDI assesses.

  • M1

    6MANAGEMENT COMMITMENT

    Senior Management maintains sufficient oversight over employee adherence to the program.

  • M12

    1HANDLING VIOLATIONS

    Program has procedures for tracking and ensuring timely completion of corrective actions for violations.

  • M12

    2HANDLING VIOLATIONS

    Program has procedures for the fair and consistent application of disciplinary actions for employee violations.

  • M12

    3HANDLING VIOLATIONS

    Senior Management takes reasonable steps to exclude employees responsible for intentional violations of export/import laws from management…

Source & revisions

First mapped
Jun 8, 2022
Last updated
Aug 11, 2026 (3d ago)
Source
Evaluation of Corporate Compliance Programs