ST0614

Source text

As written.

(12) ITT will continue to promote and publicize the availability of ITT's Ombudsman Program for reporting violations of the Act and the Regulations to ensure that violations may be readily reported via this channel, without fear of recrimination or retaliation. Complaints or concerns about matters involving compliance with the Act and the Regulations will be reported to the Director, International Trade Compliance and the SCO. The Director, International Trade Compliance will be responsible for resolving such matters. If the Director, International Trade Compliance is the subject of the complaint or concern involving the Act and the Regulations, the matter will be referred to the Chief Ethics & Compliance Officer for resolution. The Chief Ethics & Compliance Officer shall submit a semiannual report assessing the effectiveness of the Ombudsman Program relating to export matters, and will provide a copy to the Director, DTCC. This report will be in sufficient detail such that the Department may, consistent with its responsibilities under law and regulation, form an opinion about the seriousness of the alleged violations, without disclosing employee confidentiality.

Related

Other DOS standards.