The policies set out in this document are four of the foundation policies that LXGlobal Company has adopted and promulgated in order to communicate fundamental expectations and standards regarding integrity and compliance with applicable laws, including the FCPA and the anti-corruption laws of other countries.
In addition, LXGlobal has adopted and promulgated various formal internal guidelines and procedures relating to its policies. For example, the LXGlobal Guidelines for Interactions with Non-U.S. Officials contain formal internal endorsement, approval, and recordation requirements for providing gifts, entertainment, transportation, lodging, or per diem allowances to non-U.S. officials, as well as making facilitating payments.
LXGlobal's policies and guidelines are part of a rigorous, formal system of corporate governance. LXGlobal is widely known for a strong culture of corporate ethics that is understood by its managers, permeates the organization, and is reinforced by its formal system of governance and its response to even minor violations. LXGlobal's corporate culture is perpetuated by a management that stresses legal compliance on a continuous basis and that believes that a well-founded reputation for scrupulous business dealing is a priceless Company asset.
The LXGlobal System of Management Control – Basic Standards, is a comprehensive manual that describes LXGlobal's formal system of management control. The standards are implemented through a series of management controls and practices that include:
LXGlobal's Ethics Policy requires all transactions to be accurately reflected in its books and records. The LXGlobal Accounting Manual and various other LXGlobal financial reporting guidelines provide detailed instructions for keeping accurate books and records. Key financial accounting processes are standardized and well documented, and compliance with them is regularly evaluated in the course of internal and external audits, as well as self-assessments.
Those financial accounting processes provide for strict segregation of duties and approval authorities. For example, establishing bank accounts and disbursing cash are subject to strict approval and review requirements. Collectively, those checks and balances make improper booking or improper movement of significant sums of money extremely difficult.
Fundamental responsibility for overseeing compliance with law and policy rests with line management and ultimately the Company's Board of Directors. Depending on the subject matter, the staffs of various LXGlobal departments have significant roles in assisting the Board, senior line managers, and others with overseeing compliance.
LXGlobal's control processes, which are guided by LXGlobal's Controls Integrity Management System, help identify and correct weaknesses in LXGlobal's internal controls. LXGlobal's control processes help prevent and detect departures from policies, guidelines, and procedures. Those control processes include formal periodic reports to senior line management and ultimately to the Board of Directors of the Company. LXGlobal's internal controls are revised in response to detected violations, to perceived weaknesses, to changes in the law, to business changes, and to similar events. Suggested improvements to the controls, including those portions related to the FCPA and the anti-corruption laws of other countries, are always welcome.
LXGlobal encourages employees and others to report violations through various channels without fear of retaliation. LXGlobal' policies, guidelines, and procedures are enforced by disciplinary mechanisms including, when fitting, discipline of executives and managers who fail to detect violations. Violations of law and indifference to legal requirements are not tolerated at any level.
LXGlobal prepares and distributes training materials such as this Summary and conducts periodic training sessions and business practice reviews. Often employees have legitimate questions concerning the scope, interpretation, and application of laws. The Law Department is available to answer those questions.
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