Question

baker Hughes, found in violation of the FCPA, implemented a Corporate Ethics and Anti-Corruption Compliance Program....

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.

2

implementing non-required, voluntary FCPA training for the top management only.

3

putting in place a whisteblower program to encourage timely reporting of FCPA violations.

4

inviting the SEC staff to set up an office in the corporate headquarters for monitoring purposes

Homework Answers

Answer #2

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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answered by: anonymous
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