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Compliance and Ethics Criteria in Enforcement Actions

Please provide information about decisions in criminal or civil investigations or cases where a decision involving your company or client was made:

1)	Please provide information about decisions in criminal or civil investigations or cases where a decision involving your company or client was made:

a) whether or not to prosecute or charge an organization
b) concerning the nature of the charge; and/or
c) concerning the penalty,

where such decision was influenced - in whole or in part - by the organization's Ethics and Compliance Program.

2)	Recognizing that some of all of this information may not be publicly disclosed, please provide instead whatever general information for each matter that you can. When public disclosure is possible, please provide identifying information and copies of the relevant pleadings.

Criminal or Civil or Administrative
Time Period (of investigation and/or resolution)
Jurisdiction (state or federal) and District(s) (where applicable)
Nature of Matter (health care, procurement fraud, antitrust, bribery, FCPA, environment, consumer protection, etc.)
Size of Company (number of employees or facilities)
Nature of Organization (e.g., multinational, publicly held, privately held, non-profit)

3)	For each matter identified, please check as many of the criteria listed below as were presented to and considered by the government - either in a positive or negative way - concerning the organization's Ethics and Compliance Program.

Assignment and Performance of E&C program (Board, E&C Officers, etc.)

Auditing of E&C Program

Authority/Clout of E&C Program Within Company or Organization

Communications and Training

Consistency of Approach of E&C Program

Discipline for Violations

Embedding of E&C Program in Company/Organization