ST0037
The organization’s compliance and ethics program shall be promoted and enforced consistently throughout the organization through (A) appropriate incentives to perform in accordance with the compliance and ethics program; and (B) appropriate disciplinary measures for engaging in criminal conduct and…
Plain-language summary
What it actually means.
Plain-language summary forthcoming. Source text below.
Source text
As written.
The organization’s compliance and ethics program shall be promoted and enforced consistently throughout the organization through (A) appropriate incentives to perform in accordance with the compliance and ethics program; and (B) appropriate disciplinary measures for engaging in criminal conduct and for failing to take reasonable steps to prevent or detect criminal conduct.
Assessed by HEXDI
What HEXDI assesses.
- M1
3 — MANAGEMENT COMMITMENT
Policies identify the penalties for violations of export/import laws and the program.
- M1
3 — MANAGEMENT COMMITMENT
Senior Management ensures that adequate compensation, bonuses, and other incentives are available to limit turnover of employees with key…
- M12
2 — HANDLING VIOLATIONS
Program has procedures for the fair and consistent application of disciplinary actions for employee violations.
- M12
3 — HANDLING VIOLATIONS
Senior Management takes reasonable steps to exclude employees responsible for intentional violations of export/import laws from management…
Related
Other USSC standards.
Source & revisions
- First mapped
- Jun 8, 2022
- Last updated
- May 26, 2026 (34m ago)
- Source
- United States Sentencing Guidelines