Corporate Compliance Program. In order to address any deficiencies in their internal controls, compliance codes, policies, and procedures regarding compliance with the Foreign Corrupt Practices Act (“FCPA”), 15 U.S.C. §§ 78dd-1, et seq., and other applicable anti-corruption laws, Vitol Inc. and Vitol S.A. (collectively, the “Companies”), on behalf of themselves and their subsidiaries and affiliates, agree to continue to conduct, in a manner consistent with all of their obligations under this Agreement, appropriate reviews of their existing internal controls, policies, and procedures. Where necessary and appropriate, the Companies agree to adopt new, or to modify their existing compliance programs, including internal controls, compliance policies, and procedures in order to ensure that they maintain: (a) an effective system of internal accounting controls designed to ensure the making and keeping of fair and accurate books, records, and accounts; and (b) a rigorous anti-corruption compliance program that incorporates relevant internal accounting controls, as well as policies and procedures designed to effectively detect and deter violations of the FCPA and other applicable anti-corruption laws. At a minimum, this should include, but not be limited to, the following elements to the extent they are not already part of the Companies’ existing internal controls, compliance codes, policies, and procedures:
Appears in 3 contracts
Samples: Deferred Prosecution Agreement, Deferred Prosecution Agreement, Deferred Prosecution Agreement
Corporate Compliance Program. In order to address any deficiencies in their internal controls, compliance codes, policies, and procedures regarding compliance with the Foreign Corrupt Practices Act (“FCPA”), 15 U.S.C. §§ 78dd-1, et seq., 15 U.S.C. § 78m(b)(5) and other applicable anti-corruption laws, Vitol Stericycle, Inc. and Vitol S.A. (collectively, the “CompaniesCompany”), on behalf of themselves itself and their its subsidiaries and affiliates, agree agrees to continue to conduct, in a manner consistent with all of their obligations under this Agreement, appropriate reviews of their its existing internal controls, policies, and procedures. Where necessary and appropriate, the Companies agree to adopt new, or Company agrees to modify their its existing compliance programs, including internal controls, compliance policies, and procedures in order to ensure that they maintainit maintains: (a) an effective system of internal accounting controls designed to ensure the making and keeping of fair and accurate books, records, and accounts; and (b) a rigorous anti-corruption compliance program that incorporates relevant internal accounting controls, as well as policies and procedures designed to effectively detect and deter violations of the FCPA and other applicable anti-corruption laws. At a minimum, this should include, but not be limited to, the following elements to the extent they are not already part of the Companies’ existing internal controls, compliance codes, policies, and procedures:
Appears in 2 contracts
Samples: Deferred Prosecution Agreement, Deferred Prosecution Agreement
