ST1154DOJDOJ

ST1154

Another hallmark of a well-designed compliance program is the existence of an efficient and trusted mechanism by which employees can anonymously or confidentially report allegations of a breach of the company’s code of conduct, company policies, or suspected or actual misconduct. Prosecutors should…

Plain-language summary

What it actually means.

to be determined

Plain-language summary forthcoming. Source text below.

Source text

As written.

Another hallmark of a well-designed compliance program is the existence of an efficient and trusted mechanism by which employees can anonymously or confidentially report allegations of a breach of the company’s code of conduct, company policies, or suspected or actual misconduct. Prosecutors should assess whether the company’s complaint-handling process includes proactive measures to create a workplace atmosphere without fear of retaliation, appropriate processes for the submission of complaints, and processes to protect whistleblowers. Prosecutors should also assess the company’s processes for handling investigations of such complaints, including the routing of complaints to proper personnel, timely completion of thorough investigations, and appropriate follow-up and discipline.

Assessed by HEXDI

What HEXDI assesses.

  • M12

    1 — HANDLING VIOLATIONS

    Program describes the system for reporting potential violations and instructs that all company employees and Senior Management will report…

  • M12

    2 — HANDLING VIOLATIONS

    Policies encourage employees to report suspected violations without fear of reprisal.

  • M12

    3 — HANDLING VIOLATIONS

    Program requires initial hire and regular employee training on how to recognize possible violations and how to report suspected violations.

  • M12

    4 — HANDLING VIOLATIONS

    Program identifies the office and/or employee(s) available to answer questions on the legitimacy of a transaction, report possible…

  • M12

    1 — HANDLING VIOLATIONS

    Program includes a Suspicious Activity Reporting (SAR) system for collecting, analyzing, and using information on suspected violations.

  • M12

    5 — HANDLING VIOLATIONS

    Program includes an Ombudsman Program as a reporting mechanism safe from reprisals, and as a means for reporting employees to track…

Source & revisions

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