Extract to table

The Policy further provides that disclosure must be made prior to an imminent threat of disclosure or government investigation

The company must take immediate and effective steps to preserve all potentially relevant evidence and must produce responsive documents to the government on a timely basis

The company must not wait for the government to ask specific questions or issue specific requests; instead, the company must affirmatively bring relevant facts to the government's attention as they are discovered

The company must make current and, to the extent possible, former employees available for government interviews, and must not place unreasonable conditions on such availability

The company must keep the government informed of the status of its internal investigation and must provide updates as significant new facts are discovered

The company must take appropriate disciplinary action against the individuals responsible for the misconduct, up to and including termination