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⟩ Tell me are you aware of anyone who has not complied with or is not complying with the company’s code of conduct and/or compliance policies?

This question is directly associated with the compliance officer’s “monitoring” efforts to detect potential criminal conduct as per §8B2.1(5) (A) of the USSGs. It can also test compliance by managers and supervisors with internal policies requiring that any complaints from employees concerning compliance or ethics violations be reported to the compliance officer.

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