ST1160DOJDOJ

ST1160

Prosecutors should examine the extent to which senior management have clearly articulated the company’s ethical standards, conveyed and disseminated them in clear and unambiguous terms, and demonstrated rigorous adherence by example. Prosecutors should also examine how middle management, in turn,…

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 examine the extent to which senior management have clearly articulated the company’s ethical standards, conveyed and disseminated them in clear and unambiguous terms, and demonstrated rigorous adherence by example. Prosecutors should also examine how middle management, in turn, have reinforced those standards and encouraged employees to abide by them. See U.S.S.G. § 8B2.1(b)(2)(A)-(C) (the company’s “governing authority shall be knowledgeable about the content and operation of the compliance and ethics program and shall exercise reasonable oversight” of it; “[h]igh-level personnel … shall ensure that the organization has an effective compliance and ethics program” (emphasis added)).

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

    Policy Statement explains why the commitment is important for the company and to U.S. national security and foreign policy interests.

  • M1

    3 — MANAGEMENT COMMITMENT

    Policy Statement emphasizes the importance of knowledge and understanding of when and how export controls affect company products and…

  • M1

    4 — MANAGEMENT COMMITMENT

    Policy Statement is integrated into the company code of conduct.

  • M1

    5 — MANAGEMENT COMMITMENT

    Policy Statement is communicated to employees on an ongoing basis by a variety of means, to include but not limited to: company…

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