baker Hughes, found in violation of the FCPA, implemented a Corporate Ethics and Anti-Corruption Compliance Program. One component of this program, as described in a press release, included:
1 |
keeping all commercial agents previously used and requiring that they undergo ethics education. |
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2 |
implementing non-required, voluntary FCPA training for the top management only. |
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3 |
putting in place a whisteblower program to encourage timely reporting of FCPA violations. |
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4 |
inviting the SEC staff to set up an office in the corporate headquarters for monitoring purposes |
The corrext answer is (4) inviting the SEC staff to set
up an office in the corporate headquarters for monitoring
purposes.
The press release described that the company will retain a monitor to review and assess the company's compliance program for a period of three years and monitor its implementation of and compliance with new internal policies and procedures.
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