ST0449DOSDDTC

ST0449

Procedures for notification of potential violations, including use of voluntary disclosure and Ombudsman to report any violation of the company’s internal control program or U.S. export controls.

Source text

As written.

Procedures for notification of potential violations, including use of voluntary disclosure and Ombudsman to report any violation of the company’s internal control program or U.S. export controls.

Change history

When and why it changed.

Present in the original catalog

This standard has not changed since it was added.

Assessed by HEXDI

What HEXDI assesses.

  • 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

    2 — HANDLING VIOLATIONS

    SAR system has a 24-hour mechanism for employees to report suspected violations.

  • M12

    3 — HANDLING VIOLATIONS

    SAR system has an anonymous mechanism for employees to report suspected violations.

  • M12

    4 — HANDLING VIOLATIONS

    SAR system immediately notifies management of employee reports of suspected violations.

  • M12

    2 — HANDLING VIOLATIONS

    Voluntary disclosure procedures identify the situations in which the appropriate U.S. Government agency must be notified of a violation.

Source & revisions

First mapped
Jun 8, 2022
Last updated
Oct 28, 2026 (6d ago)
Source
Compliance Program Guidelines