All non-public information that might be of use to competitors or harmful to the Company, its employees or customers if disclosed is deemed confidential.
This includes considering the risk that conflicts of interest present throughout key business processes, including strategic planning, capital allocation, performance monitoring and evaluation of business units and individual business leaders.
These documents are a window through which we want to offer the public and the financial services industry a view on key risks and to share effective risk management practices that we have observed.
Some of the more effective practices I have observed include having key risk and control functions involved in each of these key processes with senior management and the board so they can provide their independent view on how business units and individual business leaders are doing at managing conflicts and promoting a culture of compliance and ethics.
Individuals are not authorized to make exceptions to these policies. He consults with individuals, corporations, governmental and non-governmental organizations and serves as an expert witness and frequent media-commentator.
Some firms enhance this process by including conflicts assessment within other processes, such as new product or business approval, conduct customer surveys for potential conflicts, or conduct periodic or ad hoc self-assessments of their business practices.
The and amendments to the Guidelines, as you know, explicitly require an effective compliance and ethics program as a mitigating factor in determining criminal sentences for corporations. Conflicts of Interest National Fuel respects the privacy and individual rights of its directors, officers and employees in the conduct of their personal affairs.
Confidentiality Purpose of the Code The purpose of this National Fuel Gas Company Code of Business Conduct and Ethics the "Code" is to define a standard for directors, officers and employees of National Fuel Gas Company and each of its wholly-owned subsidiaries collectively "National Fuel" or the "Company" for conducting Company business in an honest and ethical manner.
In addition to the high-profile cases that I mentioned earlier, conflicts of interest are at the heart of many cases that the Commission brings on a routine basis. Failure to manage conflicts of interest has been a continuing theme of financial crises and scandals since before the inception of the federal securities laws.
The staff was concerned that despite the conflict between their business responsibilities and receipt of material non-public information, the broker-dealers did not impose mitigating controls such as physical barriers, documentation or monitoring on that individual or group.
The business is the first line of defense responsible for taking, managing and supervising conflicts of interest, like other risks, effectively and in accordance with laws, regulations and the risk appetite set by the board and senior management of the whole organization.
I understand that it is against Cisco policy to retaliate against an employee for good-faith reporting of any potential or actual Code violations. Key risk and control functions, such as compliance, ethics and risk management, are the second line of defense.
Investment advisers that prefer one client over another when managing multiple accounts side-by-side, due to financial incentives or personal relationships; Portfolio management activities by fund advisers that involve risks beyond the risk tolerance levels or stated objectives in the prospectus, such as overconcentration in a single issuer or sector, purchasing illiquid securities that appear to deliver higher returns, or a mismatch of fund liquidity to an expectation of fund redemptions; Affiliations between investment advisers and broker-dealers: See your Employee Handbook, as amended from time to time, for details of administration.
The SEC and its staff have a long tradition of focusing on conflicts of interest. Finally, senior management and the board of directors need to be engaged. Gifts and Gratuities A director, officer or employee of the Company may accept gifts, meals, refreshments or entertainment as a courtesy, provided the amenity is customarily associated with legitimate business relationships and is not of such value or given with such frequency that it could influence the director's, officer's or employee's business decisions.
The Company's policies require appropriate conduct to avoid antitrust violations. Other regulators have a similarly keen focus on conflicts of interest.
Retail customers' interests potentially taking a back seat to various financial incentives of a broker-dealer or its representatives in recommendations and sales practices for new or risky products.
Directors and executive officers obtain timely guidance on ethics issues, as well as conflicts of interest, which may arise during the course of their relationship with National Fuel Gas Company. Compliance with Laws, Rules and Regulations Directors, officers and employees of National Fuel shall strive to conduct Company business in compliance with applicable laws, rules and regulations.
As in the microbial world, these viruses come in a vast array of constantly mutating formats, and if not eliminated or neutralized, even the simplest virus is a mortal threat to the body.
Finally, it is important to think proactively when it comes to conflicts of interest. Limited personal use of Company resources may be permitted, but anything more than that, and any misuse of Company resources or property, are strictly prohibited.
The Pecora hearings ofwhich focused on the causes of the crash and the subsequent banking crisis, uncovered a wide range of abusive practices on the part of banks and bank affiliates.
According to the MSRB, this proposal follows a number of civil and criminal prosecutions involving alleged fraudulent activities relating to municipal securities offerings in which undisclosed third-party payments played a role.
It should be tailored to specific conflicts in the business model and clearly set forth the governance, risk management and compliance procedures to mitigate and manage these conflicts.
Our Chief Executive Officer CEOChief Financial Officer CFO and all Finance employees are accountable for maintaining compliance with our established financial policies and for reporting our results with objectivity and the highest degree of integrity.Business & Professional Ethics for Directors, Executives & Accountants, 8e L.J.
Brooks & P. Dunn, Cengage Learning, The partners and employees of Arthur Andersen lost their jobs when the accounting partnership. Buy or Rent Business & Professional Ethics for Directors, Executives & Accountants as an eTextbook and get instant access. With VitalSource, you can save up to 80% compared to print.
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He is Executive Director of the Clarkson Centre for Business Ethics & Board Effectiveness, Director of the Professional Accounting Centre, the Master of Management & Professional Accounting Program, and the Master of Forensic Accounting Program (formerly the Diploma in Investigative & Forensic Accounting Program).Reviews: 7.
Chan is a professional accountant and serves as a non-executive director. Donna is the finance director and is an employee of the company. Esther is a legal advocate and serves as a non-executive director. All-You-Can-Learn Access with Cengage Unlimited.
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