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.
Plain-language summary
What it actually means.
Plain-language summary forthcoming. Source text below.
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.
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
- Aug 11, 2026 (3d ago)
- Source
- Compliance Program Guidelines