Mitigating Factors. The Contractor had a Trafficking in Persons compliance plan or an awareness program at the time of the violation, was in compliance with the plan, and has taken appropriate remedial actions for the violation, that may include reparation to victims for such violations.
Mitigating Factors. The Contracting Officer may consider whether Contractor had a Trafficking in Persons awareness program at the time of any violation as a mitigating factor when determining remedies.
Mitigating Factors. The Executive Director has taken into account the following facts as factors mitigating the sanctions which would otherwise have applied in the public interest:
Mitigating Factors. The CNA had a Trafficking in Persons compliance plan or an awareness program at the time of the violation, was in compliance with the plan, and has taken appropriate remedial actions for the violation, that may include reparation to victims for such violations.
Mitigating Factors. The Subcontractor had a Trafficking in Persons compliance plan or an awareness program at the time of the violation, was in compliance with the plan, and has taken appropriate remedial actions for the violation, that may include reparation to victims for such violations.
Mitigating Factors. Xxxx agreed to make early admissions with respect to the above-noted misconduct prior to the hearing of the alleged misconduct in the further amended notice of hearing.
Mitigating Factors. Xxxxxxxx agreed to make early admissions with respect to the above-noted misconduct prior to the issuance of a Notice of Hearing. DM# 2150360.v3
Mitigating Factors. 11. At the time of the trading described above, Xxxxxx had no experience in the market. Xxxxxx represents and warrants to the Commission that he was unaware of the implications of the trading described at paragraphs 9 and 10.
12. At the time of the trading described above, Xxxxxx was not an officer or director of a public corporation, and did not hold a position of special responsibility within the capital markets. Xxxxxx has voluntarily resigned as an officer and director of BLA.
13. Xxxxxx has cooperated with Staff throughout the course of Staff’s investigation and these proceedings.
14. By admitting the facts and contraventions described herein, Xxxxxx has:
a. expressed remorse for his actions; and
b. saved the OSC significant time and resources associated with conducting a fully contested hearing on the merits.
Mitigating Factors. 14. The Respondent at all times cooperated with the MFDA’s investigation of the issues that form the subject matter of this Settlement Agreement.
15. There is no evidence that clients suffered losses or other harm as a result of the Respondent’s failure to complete on-site reviews of its sub-branches pursuant to MFDA Policy No. 5 and MFDA Rule 2.5.1.
16. The Respondent hereby undertakes to comply with its branch review obligations in the future.
