Extract to table

The policy prohibits facilitation payments "except where required to protect the health or safety of personnel," and provides that any such payment must be "reported to the compliance department within 48 hours and accurately recorded in the Company's books and records

The policy states that "prior to engaging any agent, intermediary, or consultant who will interact with government officials in connection with the Company's business," the responsible business unit must "conduct appropriate due diligence to assess the integrity, qualifications, and reputation of the proposed third party

It does not specify the required due diligence steps, the documentation standards that must be satisfied, the approval workflow that must be followed, or the risk-based tiering criteria that should determine the scope and depth of due diligence

The policy does not identify a specific individual or department responsible for reviewing and approving the results of third-party due diligence, nor does it specify what categories of information must be collected and evaluated (e