I would select, "A" and conduct a risk assessment to ensure C&E program resources are reasonably budgeted. I see reviewing educational activities, conducting interviews and consulting with other departments as elements of the assessment.An understanding of the company's risks would allow me to develop a plan of action, as well as identify the resources (budget) needed for implementation.
It is reported to the CEP that the CFO is giving material non public info to a non employee family member. This is prohibited unless given an exception from the BOD. What is the first step the CEP should take:
1.) cut off computer access to the CFO
2.) meet with the CEO
3.) Report to the BoD
4.) report it to the SEC
After having a successful program up and running and employees trained on FCPA and no findings during audit and monitoring and interviewing who is the next group to be interviewed?
A policy on policies is an example of
1.) Structural Policies
2.) Substantial policies
Training for employees who to go to high risk countries is an example of what?
1.) Substantial Policy
2.) Structural Policy
Which commission defines the steps to have an effective ethics and compliance program?