ST1151DOJDOJ

ST1151

Prosecutors should assess the steps taken by the company to ensure that policies and procedures have been integrated into the organization, including through periodic training and certification for all directors, officers, relevant employees, and, where appropriate, agents and business partners.…

Assess my company

Plain-language summary

What it actually means.

to be determined

Plain-language summary forthcoming. Source text below.

Source text

As written.

Prosecutors should assess the steps taken by the company to ensure that policies and procedures have been integrated into the organization, including through periodic training and certification for all directors, officers, relevant employees, and, where appropriate, agents and business partners. Prosecutors should also assess whether the company has relayed information in a manner tailored to the audience’s size, sophistication, or subject matter expertise. Some companies, for instance, give employees practical advice or case studies to address real-life scenarios, and/or guidance on how to obtain ethics advice on a case-by-case basis as needs arise.

Assessed by HEXDI

What HEXDI assesses.

  • M3

    1 — TRAINING

    Program requires annual top-level export/import training for Board of Directors (or equivalent).

  • M3

    2 — TRAINING

    Program requires annual top-level export/import training for Senior Management.

  • M3

    3 — TRAINING

    Program requires introductory export/import compliance training for employees upon initial hire and refresher training for all employees on…

  • M3

    4 — TRAINING

    Program requires intermediate and advanced export/import control training for employees with key program responsibilities to ensure…

  • M3

    5 — TRAINING

    Program requires cross-training of backups to assume tasks of employees with key program responsibilities when the employees are on leave,…

  • M3

    6 — TRAINING

    Program includes a mentoring program in which experienced employees shadow junior employees and share their knowledge and skills with…

Related

Other DOJ standards.

Source & revisions

First mapped
Jun 8, 2022
Last updated
May 26, 2026 (15m ago)
Source
DoJ Evaluation of Corporate Compliance Programs