ethicsLINC-Compliance Checklist

ethicsLINC understands that your business must satisfy many stakeholders to be successful. Your business strategy must keep you
relevant in a marketplace that constantly demands more from you. A key area of your business strategy must include Business Ethics,
Compliance and Sustainability. These are the areas in which ethicsLINC can help! Use this simple tool to start an assessment of the
processes and procedures you have in place. ethicsLINC looks forward to helping you meet your business ethics strategy.

The checklist below shows sample questions devised to help you assess your company's current business ethics status.

Corporate Programs—Ownership and Oversight
1	Has a senior management person been assigned overall responsibility for Compliance and Business Ethics?	YES / NO
2	Is an independent hotline (helpline) in place?	YES / NO
2A	Has the hotline been effectively communicated to all employees globally?	YES / NO
2B	Have all hotline communications been translated into local languages?	YES / NO
2C	Has an appropriate process for investigations of allegations and follow up been established?	YES / NO
2D	Have all necessary steps been taken to ensure employee confidentiality?	YES / NO
2E	If applicable, are separate processes in place to address Sarbanes-Oxley issues that come into the hotline?	YES / NO
2F	Have you effectively communicated your company's "No Retaliation" policy globally?	YES / NO
3	Does the corporate office have in place and oversee an annual ethics questionnaire?	YES / NO
3A	Have you identified all appropriate groups of employees to participate in this process?	YES / NO
3B	Do you provide an opportunity for confidential responses?	YES / NO
3C	Do you have an appropriate process in place for follow up?	YES / NO
4	Do you have an annual business ethics certification in place for senior management?	YES / NO
4A	Are appropriate processes in place to ensure complete and accurate information will be accumulated?	YES / NO
4B	Is a sophisticated process of analysis and summary in place to ensure that the information being sent to senior management and the Board of Directors accurately reflects conditions throughout the company?	YES / NO
4C	Do you have an effective and formalized process for follow up in place?	YES / NO

Specific Business Ethics Programs in Place (as applicable)
	Identify whether you have formalized effective programs in place to address the sample risk areas shown below. "Effective" includes written procedures, training and communications processes, monitoring and auditing of each program (internally and externally) and mechanisms to modify programs as needed.	In Place (if applicable)
1	Anti-Corruption (FCPA)	YES / NO
2	Antitrust	YES / NO
3	Insider Trading	YES / NO
4	Hot Line	YES / NO
5	Records Management	YES / NO
6	Privacy	YES / NO
7	Environmental Compliance	YES / NO
8	Transnational Shipments (Customs, Embargoed Countries, etc.)	YES / NO
9	Data Security	YES / NO
10	Employee Health & Safety	YES / NO
11	Harassment Issues	YES / NO
12	Monitoring and Audit Programs	YES / NO
13	Vendor Compliance Programs	YES / NO
14	Political Activities Compliance	YES / NO
15	Conflicts of Interest	YES / NO
16	Diversity	YES / NO
17	Gifts and Entertainment	YES / NO
18	Intellectual Property	YES / NO
19	Kickbacks and Gratuities	YES / NO

ethicsLINC does not provide legal advice. We work with your legal counsel and translate their legal advice into achievable,
sustainable business ethics programs.