Integrity

Compliance Risk Assessment

On an annual basis, each business unit will conduct a compliance risk assessment that will be presented to the Ethics and Compliance Committee at a quarterly meeting.

Responsibilities

The compliance risk assessment will be conducted as follows:

  • The Business unit President, with guidance and support from the business unit General Counsel, Controller, and VP of Human Resources, will be responsible for the compliance risk assessment of their business unit.
  • The objective will be to identify, prioritize, and assign accountability for managing existing or potential threats related to regulatory or policy noncompliance – or ethical misconduct – that could lead to significant legal claims, fines, penalties, reputational damage, or the inability to operate in key markets.
  • The risk assessment will include: (a) a heat map displaying each risk’s relative impact and likelihood and (b) mitigation plans for each identified risk.
  • After Committee review and approval, the risk assessment will be reviewed with the CEO and CFO at least once annually during the Q1 or other quarterly deep dive, focusing on progress with mitigation plans.

Among the compliance topics that may be addressed at a given meeting are the following:

  • Labor and Employment (e.g. FLSA, Affirmative Action, EEOC, DOL, Per Diem)
  • Government Contracting (e.g. bribery/gratuities, contract pricing, Procurement Integrity, Organizational Conflicts of Interest, Mandatory Disclosure)
  • Export and Import Controls (including compliance with ITAR, EAR, OFAC, anti-boycott laws, FOCI)
  • International (e.g. FCPA, UK Anti-Bribery Law, Human Trafficking, Human Rights, Foreign Labor, Tax and Other
  • Other topics of relevance to the business

Meetings

The Committee meetings are attended by:

  • Senior Vice President and General Counsel (Executive Sponsor of the Ethics and Compliance Program and Chairman)
  • Senior Vice President, Finance and CFO
  • Senior Vice President, Human Resources
  • Vice President, Internal Audit (Secretary)
  • The four Business Unit General Counsels

In addition:

  • A senior executive of the invited business unit
  • VP of HR of the invited business unit
  • VP of Finance of the invited business unit