ST0659
[Annex of Compliance Measures] (6)(b) [the ISCO shall oversee the following specific areas:] 4. Implementation of policies and procedures encouraging NGC employees to report ITAR compliance problems without fear of reprisal. These policies and procedures should promote the NGC HOTLINE Program…
Plain-language summary
What it actually means.
Plain-language summary forthcoming. Source text below.
Source text
As written.
[Annex of Compliance Measures] (6)(b) [the ISCO shall oversee the following specific areas:] 4. Implementation of policies and procedures encouraging NGC employees to report ITAR compliance problems without fear of reprisal. These policies and procedures should promote the NGC HOTLINE Program (known within NGC as the "OpenLine") as a reporting mechanism safe from reprisals, and as a means to document the issue to be reviewed, management's action, and the result of any action taken by management in resolving the issue.
Assessed by HEXDI
What HEXDI assesses.
- 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
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.
Source & revisions
- First mapped
- Jun 8, 2022
- Last updated
- Aug 11, 2026 (3d ago)
- Source
- DDTC Consent Agreement(s)