Corporate Compliance Program. The Company represents that it has implemented or will implement a compliance and ethics program throughout its operations, including those of its majority-owned operationally- controlled affiliates, agents, and joint ventures, and those of its contractors and sub-contractors whose responsibilities include interaction with customers, investors, and business partners, determining pricing or compensation to the Company for services provided to customers, and making representations to customers, investors, or business partners, either directly or indirectly, regarding among other things, the prevention and detection of fraud-related violations of law. The Company’s efforts pursuant to this Agreement shall focus on the prevention and detection of fraud- related conduct by its employees, representatives, and agents, including but not limited to misrepresentations to and concealment of information from the Company’s customers, investors, and business partners. Implementation of this compliance and ethics program shall not be construed in any future proceeding as providing immunity or amnesty for any crimes not disclosed to the Office as of the date of this Agreement for which the Company would otherwise be responsible.
Appears in 4 contracts
Samples: Deferred Prosecution Agreement, Deferred Prosecution Agreement, Deferred Prosecution Agreement
