ST0251

7 — PROGRAM SETUP AND ADMINISTRATION

The Export/Import Compliance Council (or equivalent) reports to Board of Directors (or equivalent).

1 — TRAINING

Program requires annual top-level export/import training for Board of Directors (or equivalent).

2 — TRAINING

Program requires annual top-level export/import training for Senior Management.

6 — AUDITS AND ASSESSMENTS

Program has procedures for consultations between auditors and internal stakeholders, to include Senior Management, Board of Directors (or…

4 — AUDITS AND ASSESSMENTS

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

4 — HANDLING VIOLATIONS

Program requires assessment of whether the violations should be reported in securities filings.