ST0834DOSDDTC

ST0834

(11) Respondent will continue to promote and publicize the availability of Respondent's existing employee reporting mechanisms for reporting allegations of violations of the AECA and the ITAR to ensure that violations may be readily reported via these channels without fear of recrimination or…

Plain-language summary

What it actually means.

to be determined

Plain-language summary forthcoming. Source text below.

Source text

As written.

(11) Respondent will continue to promote and publicize the availability of Respondent's existing employee reporting mechanisms for reporting allegations of violations of the AECA and the ITAR to ensure that violations may be readily reported via these channels without fear of recrimination or retaliation. Complaints or concerns about the adequacy of Respondent's response to reported allegations, questions or similar matters involving compliance with the AECA and the ITAR will be reported to the Senior Vice President and General Counsel, or the senior official within the Office of the General Counsel responsible for AECA and ITAR compliance, and the SCO or ISCO. The Senior Vice President and General Counsel, or the senior official within the Office of the General Counsel responsible for AECA and ITAR compliance, will be responsible for resolving such matters. If the Senior Vice President and General Counsel, or the senior official within the Office of the General Counsel responsible for AECA and ITAR compliance, is the subject of the complaint or concern involving the AECA and the ITAR, the matter will be referred to the CEO for resolution. The General Counsel shall submit to the Board of Directors, or the appropriate committee thereof, a semiannual report assessing the effectiveness of Respondent's existing employee reporting mechanisms relating to export matters and will provide a copy to the Director, DTCC.

Assessed by HEXDI

What HEXDI assesses.

  • M11

    4 — AUDITS AND ASSESSMENTS

    Program has procedures for promptly communicating audit results to Board of Directors (or equivalent).

  • M12

    1 — HANDLING VIOLATIONS

    Program includes a Suspicious Activity Reporting (SAR) system for collecting, analyzing, and using information on suspected violations.

  • M12

    5 — HANDLING VIOLATIONS

    Program includes an Ombudsman Program as a reporting mechanism safe from reprisals, and as a means for reporting employees to track…

  • 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
May 26, 2026 (23m ago)
Source
DDTC Consent Agreement(s)