Investigation and Response

Appendix 3-Q: Model Internal Investigations Policy

Function

Effective Date

Pages

Revision Date

Global Compliance

[Effective Date]

4

[Revision Date]

Scope

This policy applies to [COMPANY NAME] and its subsidiaries (collectively, “[COMPANY NAME]” or the “Company”) and the directors, officers, and employees of such entities as well as those acting for or on behalf of such entities (collectively, “Covered Persons”).

Purpose

The Company takes all reports of misconduct and potential policy or code of conduct violations seriously and seeks to address them as early as possible so as to prevent damage and mitigate risk.

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