Governance
|
2011 Objectives | Progress |
|---|---|
| Code of Ethics and Business Conduct course completion by 95% of all employees | 99% completion achieved |
| Full alignment with Adequate Procedures Guidance under the UK Bribery Act; 95% completion of anti-bribery training by relevant employees in higher risk roles and geographies | Alignment activities included risk assessments, intermediary due diligence, and internal reviews by internal audit; training completed by 99% of all employees globally |
| Implementation of updated records management policy | US policy and retention schedule issued, along with online policy review and certification process for employees |
