Compliance

Prevent
Every employee has a responsibility to Prevent corruption in our company. In order to assist employees in this mission we foster a strong compliance tone from the top of our business, conduct annual trainings to increase our Compliance IQ, and conduct compliance due diligence on our third parties as part of the on-boarding process.

Detect
We know that corruption and non-compliance can exist despite the best prevention efforts. Therefore, we build systems to detect corruption within our company. To this end we have a strong Investigations function that works to detect and respond to issues and advises the Company on addressing risk; an anonymous ethics line for employees and others to report concerns; regular internal audit of all functions including Compliance; and are engaging in a process to conduct compliance due diligence on all third parties currently working with us.

Respond
Once corruption or non-compliance is detected, we move quickly to remove or remediate. Our Investigation function works efficiently to provide fair counsel and remedies that the Company can implement quickly. Internal Audit works with the business to develop action plans to address all of its findings, which they then implement. Third parties with significant findings in compliance due diligence are terminated or remediated. The performance of all of our senior management is measured by Compliance KPIs, requiring continual improvement to compliance-related issues.