ST0479DOJDOJ

ST0479

Incentive System – Has the company considered the implications of its incentives and rewards on compliance? How does the company incentivize compliance and ethical behavior? Have there been specific examples of actions taken (e.g., promotions or awards denied) as a result of compliance and ethics…

Plain-language summary

What it actually means.

to be determined

Plain-language summary forthcoming. Source text below.

Source text

As written.

Incentive System – Has the company considered the implications of its incentives and rewards on compliance? How does the company incentivize compliance and ethical behavior? Have there been specific examples of actions taken (e.g., promotions or awards denied) as a result of compliance and ethics considerations? Who determines the compensation, including bonuses, as well as discipline and promotion of compliance personnel?

Assessed by HEXDI

What HEXDI assesses.

  • M1

    1 — MANAGEMENT COMMITMENT

    Senior Management establishes a formal written international trade compliance program, principally comprised of top-level policies and…

  • M1

    1 — MANAGEMENT COMMITMENT

    Program includes a Policy Statement signed by a senior executive officer or equivalent that clearly communicates the organization’s…

  • M1

    2 — MANAGEMENT COMMITMENT

    Policies instruct that no transactions will be made contrary to export/import or other U.S. laws.

  • M1

    3 — MANAGEMENT COMMITMENT

    Policies identify the penalties for violations of export/import laws and the program.

  • M1

    1 — MANAGEMENT COMMITMENT

    Policies clearly communicate the organization’s commitment to compliance with export/import laws and ethical conduct in international trade.

  • M10

    1 — RECORDKEEPING

    Policies emphasize the need to accurately report information in company records and reports to agencies and instruct that all dealings with…

Source & revisions

First mapped
Jun 8, 2022
Last updated
May 26, 2026 (14m ago)
Source
Evaluation of Corporate Compliance Programs