E-ALERT Financial Services October 17, 2011

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "E-ALERT Financial Services October 17, 2011"

Transcription

1 E-ALERT Financial Services Octber 17, 2011 THE FINANCIAL SERVICES SECTOR AND THE BRIBERY ACT: THE ROLE OF THE UK FINANCIAL SERVICES AUTHORITY The actin we have taken against Willis Limited shws that we believe that it is vital fr firms nt nly t put in place apprpriate anti-bribery and crruptin systems and cntrls, but als t ensure that thse systems and cntrls are adequately implemented and mnitred. Tracey McDermtt, Acting Directr f Enfrcement and Financial Crime, Financial Services Authrity INTRODUCTION While the rle f the United Kingdm Serius Fraud Office (the SFO ) in enfrcing the newly enacted Bribery Act 2010 (the Bribery Act ) and the UK Ministry f Justice s Bribery Act guidance have attracted much attentin and cmmentary, the imprtant rle that the UK Financial Services Authrity (the FSA ) has t play in this regard has received less cverage. The FSA -- which regulates the financial services sectr in the UK -- recently has stepped up its effrts t ensure that regulated entities have adequate measures in place t prevent bribery and crruptin. In this nte we cnsider several recent develpments in the FSA s apprach t anti-crruptin enfrcement, including a fine impsed n Willis Limited, the publicatin f a draft financial crime guide, indicatins frm senir FSA fficials abut their apprach t inter-agency cperatin with the SFO, and prpsals fr the creatin f a new Financial Cnduct Authrity. RECENT DEVELOPMENTS IN ENFORCEMENT (a) Willis Limited On July 21, 2011, the FSA annunced that it had fined Willis Limited, an insurance brker and risk management firm, fr failings in its anti-crruptin systems and cntrls. The FSA fund that, between January 2005 and December 2009, the cmpany had failed t take reasnable care t establish and maintain effective systems fr cuntering the risks f bribery and crruptin assciated with payments made t third parties -- based in high risk jurisdictins -- wh had helped the cmpany btain r retain business frm verseas clients. The grss cmmissin earned by Willis Limited frm business intrduced by these third parties amunted t apprximately 59.7 millin. Willis Limited paid apprximately 27 millin f this in cmmissins t these third parties. Specific prblems identified by the FSA related t the cmpany s failure t: (i) establish and recrd an adequate cmmercial ratinale t supprt its payments t verseas third parties; (ii) cnduct adequate due diligence n thse parties; (iii) regularly review its relatinships with thse parties, t cnfirm whether it was necessary and apprpriate t cntinue the relatinships; and (iv) adequately mnitr cmpliance with its existing systems and cntrls. Althugh Willis had imprved its plicies in August 2008, the FSA als cncluded that the cmpany had failed t ensure thse new systems were implemented. Having cnsidered a number f factrs -- including the significant revenues attributable t the verseas third parties, the cmpany s psitin as ne f the largest brkerage and risk management firms in the UK, and the fact that the failings principally related t tw f the cmpany s mst imprtant business units -- the FSA decided t impse a fine f millin. BEIJING BRUSSELS LONDON NEW YORK SAN DIEGO SAN FRANCISCO SILICON VALLEY WASHINGTON

2 The Willis case is significant fr several reasns: 1. This is the largest fine ever impsed by the FSA in relatin t failings in financial crime systems and cntrls. The case fllws the FSA s 2009 decisin t fine AON, anther insurance brker, fr similar failings. It wuld be an exaggeratin t describe tw cases as a trend, but when cnsidered alngside recent public statements by senir FSA fficials, it is clear that the FSA is intent n expanding its enfrcement effrts in relatin t bribery and crruptin matters. 2. The case illustrates the FSA s fcus n the adequacy f systems and cntrls, rather than n whether crrupt payments actually were made. The FSA did nt seek t determine whether any f these payments were crrupt, nr did it find evidence t suggest that the cmpany s cnduct was deliberate r reckless. Fr the purpse f taking enfrcement actin, it was sufficient that it had identified failings in Willis anti-crruptin plicies and prcedures. 3. The case illustrates the value the FSA places n cperatin by firms and n early settlements. Althugh the cmpany s failings in this instance were deemed t be sufficiently serius t justify a significant fine, the FSA stated that it had given Willis a 30 percent reductin n the fine impsed, in recgnitin f the cmpany s decisin t settle at an early stage f the FSA s investigatin. Withut the discunt, the fine wuld have been 9.85 millin. The FSA als tk int accunt several mitigating factrs, including: i. the significant steps taken by the cmpany t address the failings identified by the FSA and its cmmitment t intrducing mre effective plicies and prcedures; ii. the cmpany s decisin t take disciplinary actin in relatin t staff alleged t have been invlved in making ptentially crrupt payments, r wh failed t cmply with the existing systems and cntrls; iii. the increased engagement in anti-crruptin matters demnstrated by the cmpany s senir management; and iv. the cmpany s cmmitment t carrying ut a review f past payments made t verseas third parties t identify any inapprpriate payments. It is striking that many f the same factrs are cnsidered by the SFO when deciding whether t pursue criminal prsecutins r civil sanctins in cases f verseas crruptin. (b) The Financial Crime Guide Further cnfirmatin f the FSA s fcus n anti-crruptin issues came in June, when it published a cnsultatin paper entitled Financial crime: a guide fr firms (the Guide ). The Guide sets ut examples f gd and pr practice that can be used by firms t assess the adequacy f their wn systems and prcedures in reducing their expsure t financial crime. The FSA has said that it expects firms t be aware f the guidance it cntains, and t cnsider hw t translate it int mre effective plicies and cntrls. Chapter Seven f the Guide deals exclusively with bribery and crruptin issues, and builds upn the FSA s May 2010 thematic review f bribery and crruptin in cmmercial insurance brkering. The chapter emphasizes the imprtance f cmpliance with the Bribery Act, and with the Ministry f Justice s guidance regarding adequate anti-crruptin prcedures. The cnsultatin regarding the Guide clsed n September 21, The FSA intends t publish a plicy statement befre the end f the year, which will address bth the cmments received during the cnsultatin prcess, and the final amended text f the Guide. 2

3 (c) Cperatin with the SFO As the FSA steps up its enfrcement activity in respect f crruptin matters, regulated businesses in the financial services sectr shuld be mindful f the c-peratin that exists between the FSA and SFO. Accrding t the SFO the agencies share infrmatin and cntinue t wrk clsely tgether t prevent, deter and punish financial crime. The cperatin between the tw agencies is likely t increase nw that the Bribery Act has entered int frce. While the SFO has lead respnsibility fr prsecuting cases invlving verseas crruptin, it has agreed criteria fr referring cases between, amng thers, the FSA, the plice, and the Crwn Prsecutin Service. If the SFO is made aware f a cmpany s deficient anti-crruptin plicies and prcedures, there is a distinct likelihd that it will place the cmpany under scrutiny. Expsure t an FSA fine fr prcedural and systems failures therefre carries with it the risk f an SFO investigatin and a ptential criminal sanctin fr the firm and the individuals invlved. (d) The Financial Cnduct Authrity The UK Gvernment recently has prpsed significant changes t the architecture f financial services regulatin, including the creatin f a new Financial Cnduct Authrity (the FCA ). A draft Financial Services Bill, published in June 2011, prpses the transfer f respnsibility fr the preventin f financial crime within the financial services sectr frm the FSA t the FCA. Fllwing a perid f pre-legislative scrutiny f the draft Bill, it is expected that the Gvernment will frmally intrduce a Bill t Parliament befre the end f the year. Despite these anticipated changes, the existing financial crime team in the FSA has pledged that there will be a lt f cntinuity in [their] wrk t tackle financial crime, and it is envisaged that many FSA emplyees will mve t the FCA when it is established. CONCLUSION The anti-crruptin enfrcement landscape in the UK has changed significantly in recent years. The Bribery Act has refrmed the legislative framewrk f anti-crruptin ffences, and several agencies, including the SFO and the FSA, have shwn a renewed cmmitment t bringing enfrcement actins against individuals and crpratins invlved in crrupt cnduct and thse wh allw such practices t flurish unchecked. The Bribery Act, which came int frce n July 1, 2011, makes a cmpany that carries n all r part f its business in the UK liable fr failing t prevent bribes being paid by assciated persns -- thse perfrming services fr r n behalf f the cmpany -- unless the cmpany can demnstrate that it had develped and implemented adequate prcedures t prevent bribery. Guidance published by the UK Ministry f Justice under Sectin 9 f the Bribery Act sets ut six principles that are intended t help rganizatins develp and implement such prcedures. The FSA has indicated that, when cnsidering the adequacy f their systems, regulated entities shuld have regard t these principles. THE SIX PRINCIPLES The UK Gvernment cnsiders that prcedures put in place by cmmercial rganizatins t prevent bribery being cmmitted n their behalf shuld be infrmed by six principles: 1. A cmmercial rganizatin s prcedures t prevent bribery by persns assciated with it are prprtinate t the bribery risks it faces and t the nature, scale and cmplexity f the cmmercial rganizatin s activities. They are als clear, practical, accessible, effectively implemented and enfrced. 2. The tp-level management f a cmmercial rganizatin (be it a bard f directrs, the wners r any ther equivalent bdy r persn) are cmmitted t preventing bribery by persns assciated with it. They fster a culture within the rganizatin in which bribery is never acceptable. 3

4 3. The cmmercial rganizatin assesses the nature and extent f its expsure t ptential external and internal risks f bribery n its behalf by persns assciated with it. The assessment is peridic, infrmed and dcumented. 4. The cmmercial rganizatin applies due diligence prcedures, taking a prprtinate and risk based apprach, in respect f persns wh perfrm r will perfrm services fr r n behalf f the rganizatin, in rder t mitigate identified bribery risks. 5. The cmmercial rganizatin seeks t ensure that its bribery preventin plicies and prcedures are embedded and understd thrughut the rganizatin thrugh internal and external cmmunicatin, including training, that is prprtinate t the risks it faces. 6. The cmmercial rganizatin mnitrs and reviews prcedures designed t prevent bribery by persns assciated with it and makes imprvements where necessary. Many firms in the financial sectr -- particularly thse perating r investing in the US -- already have implemented plicies and prcedures t address their expsure under the US Freign Crrupt Practices Act (the FCPA ). Many als already have reviewed and updated their FCPA-related plicies and prcedures in light f the Bribery Act. The firms that have nt dne s already, despite their UK presence r UK related investments, will need t review their existing plicies and prcedures t take accunt f their ptential expsure under the Bribery Act and ther legislatin such as the UK Prceeds f Crime Act The fllwing steps shuld be undertaken as swiftly as pssible: Assess yur risk - identify the crruptin risks that arise by virtue f the nature f yur glbal business activities and ther investments. Design and implement an apprpriate cmpliance prgram r mdify an existing prgram t ensure cmpliance with the Bribery Act. Yu will need t pay attentin in that cnnectin t the principles set ut in the adequate prcedures guidance issued by the UK Ministry f Justice. As part f that prcess, firms in the financial sectr shuld -- seek t identify the bribery related risks that they actually are facing as a result f their peratins; develp targeted appraches t mitigating such risks; develp an apprpriate due diligence prgram fr use in cnnectin with prpsed acquisitins and investments and intermediaries; review cmmercial agreements with third parties (such as intermediaries) whse actins may create liability fr them; develp a clear plicy fr dealing with bribery related issues that have been reprted t them, whether the infrmatin cmes frm a whistleblwer r sme ther surce; make sure that thse within the firm that can affect the firm s bribery related risk prfile understand their legal respnsibilities and the firm s expectatins f them; and peridically re-evaluate their bribery related plicies and prcedures t ensure that they are, and will be deemed t be, fit fr purpse in the event their adequacy is called int questin. Cvingtn has develped a large and sphisticated crss-ffice practice t help clients prevent, detect and investigate bribery and enhance anti-crruptin cmpliance. Our experience includes designing cmpliance prgrams fr individual cmpanies, investigating pssible wrngding and cnducting cmpliance GAP analyses with the gal f identifying deficiencies in the plicies and prcedures individual cmpanies have implemented t ensure cmpliance with measures such as the US Freign Crrupt Practices Act, UK Bribery Act 2010 and cmpanin measures in ther cuntries. 4

5 Apprximately 25 Cvingtn lawyers -- wrking frm ur ffices in Beijing, Brussels, Lndn, New Yrk, San Francisc and Washingtn -- spend all r a very substantial part f their time wrking n bribery related matters. Cvingtn s anti-bribery lawyers wrk clsely with lawyers in the firm s financial services practice in assessing the particular needs f financial services clients. If yu have any questins cncerning the material discussed in this client alert, please cntact the fllwing members f ur financial services and anti-crruptin practice grups: Rbert Amaee (Anti-Crruptin) +44.(0) Simn Currie (Financial Services) +44.(0) Ian Redfearn (Anti-Crruptin) +44.(0) This infrmatin is nt intended as legal advice. Readers shuld seek specific legal advice befre acting with regard t the subjects mentined herein. Cvingtn & Burling LLP, an internatinal law firm, prvides crprate, litigatin and regulatry expertise t enable clients t achieve their gals. This cmmunicatin is intended t bring relevant develpments t ur clients and ther interested clleagues. Please send an t if yu d nt wish t receive future s r electrnic alerts Cvingtn & Burling LLP, 265 Strand, Lndn WC2R 1BH. All rights reserved. 5

Key Steps for Organizations in Responding to Privacy Breaches

Key Steps for Organizations in Responding to Privacy Breaches Key Steps fr Organizatins in Respnding t Privacy Breaches Purpse The purpse f this dcument is t prvide guidance t private sectr rganizatins, bth small and large, when a privacy breach ccurs. Organizatins

More information

Creating an Ethical Culture and Protecting Your Bottom Line:

Creating an Ethical Culture and Protecting Your Bottom Line: Creating an Ethical Culture and Prtecting Yur Bttm Line: Best Practices fr Crprate Cdes f Cnduct Nte: The infrmatin belw and all infrmatin n this website is nt meant t be taken as legal advice. Please

More information

Draft for consultation

Draft for consultation Draft fr cnsultatin Draft Cde f Practice n discipline and grievance May 2008 Further infrmatin is available frm www.acas.rg.uk CONSULTATION ON REVISED ACAS CODE OF PRACTICE ON DISCIPLINE AND GRIEVANCE

More information

Personal Data Security Breach Management Policy

Personal Data Security Breach Management Policy Persnal Data Security Breach Management Plicy 1.0 Purpse The Data Prtectin Acts 1988 and 2003 impse bligatins n data cntrllers in Western Care Assciatin t prcess persnal data entrusted t them in a manner

More information

Corporate Standards for data quality and the collation of data for external presentation

Corporate Standards for data quality and the collation of data for external presentation The University f Kent Crprate Standards fr data quality and the cllatin f data fr external presentatin This paper intrduces a set f standards with the aim f safeguarding the University s psitin in published

More information

MANITOBA SECURITIES COMMISSION STRATEGIC PLAN 2013-2016

MANITOBA SECURITIES COMMISSION STRATEGIC PLAN 2013-2016 MANITOBA SECURITIES COMMISSION STRATEGIC PLAN 2013-2016 The Manitba Securities Cmmissin (the Cmmissin) is a divisin f the Manitba Financial Services Agency (MFSA). The ther divisin is the Financial Institutins

More information

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM WB-DEC

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM WB-DEC UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washingtn, D.C. 20549 FORM WB-DEC DECLARATION OF ORIGINAL INFORMATION SUBMITTED PURSUANT TO SECTION 21F OF THE SECURITIES EXCHANGE ACT OF 1934 A. SUBMITTER

More information

FINANCIAL SERVICES FLASH REPORT

FINANCIAL SERVICES FLASH REPORT FINANCIAL SERVICES FLASH REPORT Draft Regulatry Cmpliance Management Guideline Released by the Office f the Superintendent f Financial Institutins May 5, 2014 On April 30, 2014, the Office f the Superintendent

More information

National Australia Bank Limited Group Disclosure & External Communications Policy

National Australia Bank Limited Group Disclosure & External Communications Policy Natinal Australia Bank Limited Grup Disclsure & External Cmmunicatins Plicy Grup Disclsure & External Cmmunicatins Plicy Page 2 f 7 Grup Disclsure & External Cmmunicatins Plicy ( the Plicy ) 1. Overview

More information

Audit Committee Charter

Audit Committee Charter Audit Cmmittee Charter Membership The Audit Cmmittee (the "Cmmittee") f the Bard f Directrs (the "Bard") f Philip Mrris Internatinal Inc. (the "Cmpany") shall cnsist f at least three directrs all f whm

More information

FREQUENTLY ASKED QUESTIONS ON THE EUCOMED ETHICAL BUSINESS LOGO

FREQUENTLY ASKED QUESTIONS ON THE EUCOMED ETHICAL BUSINESS LOGO Rue Jseph II, 40 www.eucmed.rg FREQUENTLY ASKED QUESTIONS ON THE EUCOMED ETHICAL BUSINESS LOGO Q1: What is the Eucmed Ethical Business Lg? A1: The Ethical Business Lg is a Lg licensed by Eucmed, the Eurpean

More information

Research Report. Abstract: The Emerging Intersection Between Big Data and Security Analytics. November 2012

Research Report. Abstract: The Emerging Intersection Between Big Data and Security Analytics. November 2012 Research Reprt Abstract: The Emerging Intersectin Between Big Data and Security Analytics By Jn Oltsik, Senir Principal Analyst With Jennifer Gahm Nvember 2012 2012 by The Enterprise Strategy Grup, Inc.

More information

CASSOWARY COAST REGIONAL COUNCIL POLICY ENTERPRISE RISK MANAGEMENT

CASSOWARY COAST REGIONAL COUNCIL POLICY ENTERPRISE RISK MANAGEMENT CASSOWARY COAST REGIONAL COUNCIL POLICY ENTERPRISE RISK MANAGEMENT Plicy Number: 2.20 1. Authrity Lcal Gvernment Act 2009 Lcal Gvernment Regulatin 2012 AS/NZS ISO 31000-2009 Risk Management Principles

More information

OUR DISCIPLINARY POLICY

OUR DISCIPLINARY POLICY OUR DISCIPLINARY POLICY WHO is this plicy fr? Channel 4 emplyees wh ve passed their prbatinary perid Channel 4 managers This plicy des nt frm part f any emplyee s cntract f emplyment and we may amend it

More information

Small Business, Enterprise and Employment Bill: Insolvency fact sheets Contents

Small Business, Enterprise and Employment Bill: Insolvency fact sheets Contents 1 Small Business, Enterprise and Emplyment Bill: Inslvency fact sheets Cntents Directr Disqualificatin and Inslvency General Aims... 2 Administratin: sales t cnnected persns (prepack administratins)...

More information

Framework Agreement between the Department of Health and Public Health England. Annex C: Public-Facing Communications

Framework Agreement between the Department of Health and Public Health England. Annex C: Public-Facing Communications Framewrk Agreement between the Department f Health and Public Health England Annex C: Public-Facing Cmmunicatins Framewrk Agreement between the Department f Health and Public Health England: Annex C Annex

More information

Network Security Trends in the Era of Cloud and Mobile Computing

Network Security Trends in the Era of Cloud and Mobile Computing Research Reprt Abstract: Netwrk Security Trends in the Era f Clud and Mbile Cmputing By Jn Oltsik, Senir Principal Analyst and Bill Lundell, Senir Research Analyst With Jennifer Gahm, Senir Prject Manager

More information

April 2011. In addition, we encounter valuation practices that present concerns in certain contexts, including:

April 2011. In addition, we encounter valuation practices that present concerns in certain contexts, including: April 2011 We wanted t take the pprtunity prvided by the AICPA s recent release f the expsure draft Practice Aid t share with ur clients and friends sme bservatins and best practice suggestins n this tpic.

More information

Internal Audit Charter and operating standards

Internal Audit Charter and operating standards Internal Audit Charter and perating standards 2 1 verview This dcument sets ut the basis fr internal audit: (i) the Internal Audit charter, which establishes the framewrk fr Internal Audit; and (ii) hw

More information

THE CITY UNIVERSITY OF NEW YORK IDENTITY THEFT PREVENTION PROGRAM

THE CITY UNIVERSITY OF NEW YORK IDENTITY THEFT PREVENTION PROGRAM THE CITY UNIVERSITY OF NEW YORK IDENTITY THEFT PREVENTION PROGRAM 1. Prgram Adptin The City University f New Yrk (the "University") develped this Identity Theft Preventin Prgram (the "Prgram") pursuant

More information

Change Management Process

Change Management Process Change Management Prcess B1.10 Change Management Prcess 1. Intrductin This plicy utlines [Yur Cmpany] s apprach t managing change within the rganisatin. All changes in strategy, activities and prcesses

More information

10 th May 2010. Dear Peter, Re: Audit Quality in Australia: A Strategic Review

10 th May 2010. Dear Peter, Re: Audit Quality in Australia: A Strategic Review 10 th May 2010 Mr. Peter Levy Audit Quality Strategic Review Crpratins and Financial Services Divisin The Treasury Langtn Crescent PARKES ACT 2600 Dear Peter, Re: Audit Quality in Australia: A Strategic

More information

CMS Eligibility Requirements Checklist for MSSP ACO Participation

CMS Eligibility Requirements Checklist for MSSP ACO Participation ATTACHMENT 1 CMS Eligibility Requirements Checklist fr MSSP ACO Participatin 1. General Eligibility Requirements ACO participants wrk tgether t manage and crdinate care fr Medicare fee-fr-service beneficiaries.

More information

Data Protection: Regulating Cyber Security. Jonathan Bamford Head of Strategic Liaison

Data Protection: Regulating Cyber Security. Jonathan Bamford Head of Strategic Liaison Data Prtectin: Regulating Cyber Security Jnathan Bamfrd Head f Strategic Liaisn Hw des DP regulatin affect cyber security? Data Prtectin Act 1998: apprpriate security Privacy and Electrnic Cmmunicatin

More information

CF CCO Munich, May 2, 2007 Corporate Compliance Office (CCO)

CF CCO Munich, May 2, 2007 Corporate Compliance Office (CCO) CF CCO Munich, May 2, 2007 Crprate Cmpliance Office (CCO) Distributin: Chairmen f the Supervisry and Managing Bards; Executive Vice Presidents, Senir Vice Presidents; Grup Executive Managements, Vice Presidents;

More information

Data Protection Act Data security breach management

Data Protection Act Data security breach management Data Prtectin Act Data security breach management The seventh data prtectin principle requires that rganisatins prcessing persnal data take apprpriate measures against unauthrised r unlawful prcessing

More information

MSB FINANCIAL CORP. MILLINGTON BANK AUDIT COMMITTEE CHARTER

MSB FINANCIAL CORP. MILLINGTON BANK AUDIT COMMITTEE CHARTER MSB FINANCIAL CORP. MILLINGTON BANK AUDIT COMMITTEE CHARTER This Audit Cmmittee Charter has been amended as f July 17, 2015. The Audit Cmmittee shall review and reassess this Charter annually and recmmend

More information

Malpractice and Maladministration Policy

Malpractice and Maladministration Policy TR340 Malpractice and Maladministratin Plicy This plicy aims t: Define malpractice and maladministratin in the cntext f CIM/CAM studying members, Accredited study centres (ASCs), examinatin centres, invigilatrs

More information

Sources of Federal Government and Employee Information

Sources of Federal Government and Employee Information Inf Surce Surces f Federal Gvernment and Emplyee Infrmatin Ridley Terminals Inc. TABLE OF CONTENTS General Infrmatin Intrductin t Inf Surce Backgrund Respnsibilities Institutinal Functins, Prgram and Activities

More information

WHITE PAPER: UNIVERSITY AND COLLEGE COMPLIANCE WITH THE FOREIGN CORRUPT PRACTICES ACT IN CONNECTION WITH FOREIGN ACADEMIC PROGRAMS

WHITE PAPER: UNIVERSITY AND COLLEGE COMPLIANCE WITH THE FOREIGN CORRUPT PRACTICES ACT IN CONNECTION WITH FOREIGN ACADEMIC PROGRAMS WHITE PAPER: UNIVERSITY AND COLLEGE COMPLIANCE WITH THE FOREIGN CORRUPT PRACTICES ACT IN CONNECTION WITH FOREIGN ACADEMIC PROGRAMS By Sean R. Kelly, Esq. DanaLynn T. Cla, Esq. Saiber, LLC 18 Clumbia Turnpike,

More information

Research Report. Abstract: Advanced Malware Detection and Protection Trends. September 2013

Research Report. Abstract: Advanced Malware Detection and Protection Trends. September 2013 Research Reprt Abstract: Advanced Malware Detectin and Prtectin Trends By Jn Oltsik, Senir Principal Analyst With Jennifer Gahm, Senir Prject Manager September 2013 2013 by The Enterprise Strategy Grup,

More information

Municipal Advisor Registration

Municipal Advisor Registration FACT SHEET Municipal Advisr Registratin SEC Open Meeting Sept. 18, 2013 The Securities and Exchange Cmmissin tday will cnsider whether t adpt a rule that wuld establish a permanent registratin regime fr

More information

ONGOING FEEDBACK AND PERFORMANCE MANAGEMENT. A. Principles and Benefits of Ongoing Feedback

ONGOING FEEDBACK AND PERFORMANCE MANAGEMENT. A. Principles and Benefits of Ongoing Feedback ONGOING FEEDBACK AND PERFORMANCE MANAGEMENT A. Principles and Benefits f Onging Feedback While it may seem like an added respnsibility t managers already "full plate," managers that prvide nging feedback

More information

Heythrop College Disciplinary Procedure for Support Staff

Heythrop College Disciplinary Procedure for Support Staff Heythrp Cllege Disciplinary Prcedure fr Supprt Staff Intrductin 1. This prcedural dcument des nt apply t thse academic-related staff wh are mentined in the Cllege s Ordinance, namely the Librarian and

More information

INTERNATIONAL STANDARD ON AUDITING 265 COMMUNICATING DEFICIENCIES IN INTERNAL CONTROL TO THOSE CHARGED WITH GOVERNANCE AND MANAGEMENT CONTENTS

INTERNATIONAL STANDARD ON AUDITING 265 COMMUNICATING DEFICIENCIES IN INTERNAL CONTROL TO THOSE CHARGED WITH GOVERNANCE AND MANAGEMENT CONTENTS INTERNATIONAL STANDARD ON AUDITING 265 COMMUNICATING DEFICIENCIES IN INTERNAL CONTROL TO THOSE CHARGED WITH GOVERNANCE AND MANAGEMENT (Effective fr audits f financial statements fr perids beginning n r

More information

Bl$wing the Whistle $n the New Whistlebl$wer Pr$tecti$ns Created by the D$dd-Frank Act. By: Michael James L$mbardin$

Bl$wing the Whistle $n the New Whistlebl$wer Pr$tecti$ns Created by the D$dd-Frank Act. By: Michael James L$mbardin$ Oct$ber 22, 2010 Bl$wing the Whistle $n the New Whistlebl$wer Pr$tecti$ns Created by the D$dd-Frank Act By: Michael James L$mbardin$ The "D&dd-Frank Wall Street Ref&rm and C&nsumer Pr&tecti&n Act" (D&dd-Frank)

More information

HSBC s Swiss Private Bank Progress Update - January 2015

HSBC s Swiss Private Bank Progress Update - January 2015 HSBC s Swiss Private Bank Prgress Update - January 2015 Overview HSBC Glbal Private Banking ( GPB ) and in particular its Swiss private bank have undergne a radical transfrmatin in recent years. HSBC has

More information

Briefing 4 Inquests and the disclosure of information to the coroner

Briefing 4 Inquests and the disclosure of information to the coroner briefing February 2013 The Francis Reprt Briefing 4 Inquests and the disclsure f infrmatin t the crner Key chapters Key recmmendatins 2, 11, 14, 22 274, 45, 273, 282, 283, 17 There is a requirement nt

More information

Multi-Year Accessibility Policy and Plan for NSF Canada and NSF International Strategic Registrations Canada Company, 2014-2021

Multi-Year Accessibility Policy and Plan for NSF Canada and NSF International Strategic Registrations Canada Company, 2014-2021 Multi-Year Accessibility Plicy and Plan fr NSF Canada and NSF Internatinal Strategic Registratins Canada Cmpany, 2014-2021 This 2014-21 accessibility plan utlines the plicies and actins that NSF Canada

More information

AMWA Chapter Subgroups on LinkedIn Guidance for Subgroup Managers and Chapter Leaders, updated 2-12-15

AMWA Chapter Subgroups on LinkedIn Guidance for Subgroup Managers and Chapter Leaders, updated 2-12-15 AMWA Chapter Subgrups n LinkedIn Guidance fr Subgrup Managers and Chapter Leaders, updated 2-12-15 1. Chapters may nt have an independent grup n LinkedIn, Facebk, r ther scial netwrking site. AMWA prvides

More information

Research Report. Abstract: Security Management and Operations: Changes on the Horizon. July 2012

Research Report. Abstract: Security Management and Operations: Changes on the Horizon. July 2012 Research Reprt Abstract: Security Management and Operatins: Changes n the Hrizn By Jn Oltsik, Senir Principal Analyst With Kristine Ka and Jennifer Gahm July 2012 2012, The Enterprise Strategy Grup, Inc.

More information

ANTI MONEY LAUNDERING POLICY

ANTI MONEY LAUNDERING POLICY What is mney laundering? ANTI MONEY LAUNDERING POLICY 1. Mney laundering is where mney btained, as a result f a crime, is used t pay fr services r gds. Althugh the term mney laundering is usually assciated

More information

Army DCIPS Employee Self-Report of Accomplishments Overview Revised July 2012

Army DCIPS Employee Self-Report of Accomplishments Overview Revised July 2012 Army DCIPS Emplyee Self-Reprt f Accmplishments Overview Revised July 2012 Table f Cntents Self-Reprt f Accmplishments Overview... 3 Understanding the Emplyee Self-Reprt f Accmplishments... 3 Thinking Abut

More information

7 October 2011. Re: Themed Inspection into Third Party Personal Injury Claims. Dear

7 October 2011. Re: Themed Inspection into Third Party Personal Injury Claims. Dear 7 Octber 2011 Re: Themed Inspectin int Third Party Persnal Injury Claims Dear During 2011 the Central Bank f Ireland ( Central Bank ) undertk a themed inspectin prject in relatin t the prcessing f third

More information

IFRS Discussion Group

IFRS Discussion Group IFRS Discussin Grup Reprt n the Public Meeting February 26, 2014 The IFRS Discussin Grup is a discussin frum nly. The Grup s purpse is t assist the Accunting Standards Bard (AcSB) regarding issues arising

More information

Hearing Loss Regulations Vendor information pack

Hearing Loss Regulations Vendor information pack Hearing Lss Regulatins Vendr infrmatin pack Nvember 2010 Implementing the Accident Cmpensatin (Apprtining Entitlements fr Hearing Lss) Regulatins 2010 The Minister fr ACC, the Hn. Dr Nick Smith, has annunced

More information

Audit Committee Charter. St Andrew s Insurance (Australia) Pty Ltd St Andrew s Life Insurance Pty Ltd St Andrew s Australia Services Pty Ltd

Audit Committee Charter. St Andrew s Insurance (Australia) Pty Ltd St Andrew s Life Insurance Pty Ltd St Andrew s Australia Services Pty Ltd Audit Cmmittee Charter St Andrew s Insurance (Australia) Pty Ltd St Andrew s Life Insurance Pty Ltd St Andrew s Australia Services Pty Ltd Versin 2.0, 22 February 2016 Apprver Bard f Directrs St Andrew

More information

AHI. Foreign Pre-Approval Inspections (PAIs) Points to Consider

AHI. Foreign Pre-Approval Inspections (PAIs) Points to Consider AHI Freign Pre-Apprval Inspectins (PAIs) Pints t Cnsider The fllwing suggestins are intended t prvide spnsr guidance fr timeliness and predictability f freign PAIs. The FDA Center fr Veterinary Medicine

More information

COMPREHENSIVE SAFETY ASSESSMENT INSTRUCTIONS for STUDY ABROAD PROGRAMS

COMPREHENSIVE SAFETY ASSESSMENT INSTRUCTIONS for STUDY ABROAD PROGRAMS COMPREHENSIVE SAFETY ASSESSMENT INSTRUCTIONS fr STUDY ABROAD PROGRAMS Belw is a list f items t address and questins that need t be addressed in the cmprehensive safety assessment. In additin t the safety

More information

POLICY 1390 Information Technology Continuity of Business Planning Issued: June 4, 2009 Revised: June 12, 2014

POLICY 1390 Information Technology Continuity of Business Planning Issued: June 4, 2009 Revised: June 12, 2014 State f Michigan POLICY 1390 Infrmatin Technlgy Cntinuity f Business Planning Issued: June 4, 2009 Revised: June 12, 2014 SUBJECT: APPLICATION: PURPOSE: CONTACT AGENCY: Plicy fr Infrmatin Technlgy (IT)

More information

CFD AND SPOT FOREX TERMS: DEPOSIT ACCOUNTS

CFD AND SPOT FOREX TERMS: DEPOSIT ACCOUNTS 1. Structure 1.1 When we engage in cfd r spt frex trading with yu, we d s n the basis f: - ur General Terms; these terms, i.e. ur CFD and Spt Frex Terms. 1.2 The CFD and Spt Frex Terms deal with matters

More information

Legal Services Act: New forms of practice and regulation

Legal Services Act: New forms of practice and regulation Legal Services Act: New frms f practice and regulatin Cnsultatin paper 16 Better regulatin: A new apprach t regulating legal services firms and slicitrs 6/1/2009 Page 1 f 12 www.sra.rg.uk Cntents Intrductin...3

More information

Request for Resume (RFR) CATS II Master Contract. All Master Contract Provisions Apply

Request for Resume (RFR) CATS II Master Contract. All Master Contract Provisions Apply Sectin 1 General Infrmatin RFR Number: (Reference BPO Number) Functinal Area (Enter One Only) F50B3400026 7 Infrmatin System Security Labr Categry A single supprt resurce may be engaged fr a perid nt t

More information

Financial Accountability Handbook

Financial Accountability Handbook Financial Accuntability Handbk >> Vlume 4 Mnitring/assessment Infrmatin Sheet 4.2 Statement by Chief Finance Officer Intrductin Accuntable fficers and statutry bdies are respnsible fr the efficient, effective

More information

CROPREDY SURGERY Dr J Wright & Dr B Tucker

CROPREDY SURGERY Dr J Wright & Dr B Tucker CROPREDY SURGERY Dr J Wright & Dr B Tucker POLICY - COMPLAINTS Intrductin The bjectives f the cmplaints plicy are as fllws. Any cmplaint is dealt with in an effective and timely manner The cmplainant is

More information

SECTION I.4 AUDIT ENGAGEMENT WORKING PAPERS

SECTION I.4 AUDIT ENGAGEMENT WORKING PAPERS SECTION I.4 AUDIT ENGAGEMENT WORKING PAPERS Ref. Plicy and Practice Requirements IIA Standards references I.4 1 Plicy: Wrking papers shall be prepared fr each audit engagement t recrd wrk perfrmed and

More information

UNIVERSITY OF CALIFORNIA MERCED PERFORMANCE MANAGEMENT GUIDELINES

UNIVERSITY OF CALIFORNIA MERCED PERFORMANCE MANAGEMENT GUIDELINES UNIVERSITY OF CALIFORNIA MERCED PERFORMANCE MANAGEMENT GUIDELINES REFERENCES AND RELATED POLICIES A. UC PPSM 2 -Definitin f Terms B. UC PPSM 12 -Nndiscriminatin in Emplyment C. UC PPSM 14 -Affirmative

More information

SEC FLASH REPORT. June 28, 2011

SEC FLASH REPORT. June 28, 2011 SEC FLASH REPORT The Securities and Exchange Cmmissin Issues Prpsal t Strengthen Audits and Reprting f Brker-Dealers t Prtect Custmer Assets and Requests Cmments June 28, 2011 On June 15, 2011, the U.S.

More information

Public consultation paper

Public consultation paper Public cnsultatin paper Nvember 2012 Public cnsultatin n guidelines fr prfessinal indemnity insurance arrangements fr nurses and nurse practitiners. Please prvide feedback by email t: nmbafeedback@ahpra.gv.au

More information

PENETRATION TEST OF THE INDIAN HEALTH SERVICE S COMPUTER NETWORK

PENETRATION TEST OF THE INDIAN HEALTH SERVICE S COMPUTER NETWORK Department f Health and Human Services OFFICE OF INSPECTOR GENERAL PENETRATION TEST OF THE INDIAN HEALTH SERVICE S COMPUTER NETWORK Inquiries abut this reprt may be addressed t the Office f Public Affairs

More information

Attendance Policy 2016

Attendance Policy 2016 Attendance Plicy 2016 Date f Plicy: March 2016 Date f Review: March 2016 Aims and Targets The Gverning bdy f New Hall Primary and Children s Centre places a high pririty n achieving standards and feel

More information

PUBLIC COMPANY ACCOUNTING OVERSIGHT BOARD

PUBLIC COMPANY ACCOUNTING OVERSIGHT BOARD 1666 K Street, N.W. Washingtn, DC 20006 Telephne: (202) 207-9100 Facsimile: (202) 862-8433 www.pcabus.rg PUBLIC COMPANY ACCOUNTING OVERSIGHT BOARD ) ) In the Matter f ) PCAOB Release N.104-2014-166 KPMG

More information

Environment Protection Authority

Environment Protection Authority Envirnment Prtectin Authrity EPA Cmplaints Management Plicy Intrductin This plicy sets ut the purpse, principles and prcess fr hw custmer feedback, including cmplaints, will be managed in the EPA t imprve

More information

LINCOLNSHIRE POLICE Policy Document

LINCOLNSHIRE POLICE Policy Document LINCOLNSHIRE POLICE Plicy Dcument 1. POLICY IDENTIFICATION PAGE POLICY TITLE: ICT CHANGE & RELEASE MANAGEMENT POLICY POLICY REFERENCE NO: PD 186 POLICY OWNERSHIP: ACPO Cmmissining Officer: Prtfli / Business-area

More information

INSTRUCTIONS UNITED KINGDOM CDOT JURISDICTION ADDENDUM SELF- CERTIFICATION FOR ENTITIES

INSTRUCTIONS UNITED KINGDOM CDOT JURISDICTION ADDENDUM SELF- CERTIFICATION FOR ENTITIES INSTRUCTIONS UNITED KINGDOM CDOT JURISDICTION ADDENDUM SELF- CERTIFICATION FOR ENTITIES United Kingdm Crwn Dependencies & Overseas Territries (UK CDOT) Overview T cmply with the United Kingdm (UK) and

More information

SECTION J QUALITY ASSURANCE AND IMPROVEMENT PROGRAM

SECTION J QUALITY ASSURANCE AND IMPROVEMENT PROGRAM Audit Manual Sectin J SECTION J QUALITY ASSURANCE AND IMPROVEMENT PROGRAM Ref. Plicy and Practice Requirements IIA Standards and Other references J 1 Plicy: The Head f Internal Audit shall develp and maintain

More information

A Comparison of UK and Chinese Broking Regulation

A Comparison of UK and Chinese Broking Regulation A Cmparisn f UK and Chinese Brking Regulatin David Cupe Partner +44 (0)203 553 4884 david.cupe@ec3legal.cm The fllwing tables are a cmparisn f UK and Chinese brking regulatins including the Llyd s regulatins.

More information

Communicating Deficiencies in Internal Control to Those Charged with Governance and Management

Communicating Deficiencies in Internal Control to Those Charged with Governance and Management Internatinal Auditing and Assurance Standards Bard ISA 265 April 2009 Internatinal Standard n Auditing Cmmunicating Deficiencies in Internal Cntrl t Thse Charged with Gvernance and Management Internatinal

More information

How to: Hold Effective Board of Directors Meetings

How to: Hold Effective Board of Directors Meetings Hw t: Hld Effective Bard f Directrs Meetings Intrductin The C-perative Crpratins Act prvides specific guidance n hw t elect directrs, what cnstitutes qurum, and where meetings can be cnducted, but there

More information

Process for Responding to Privacy Breaches

Process for Responding to Privacy Breaches Prcess fr Respnding t Privacy Breaches 1. Purpse 1.1 This dcument sets ut the steps that ministries must fllw when respnding t a privacy breach. It must be read in cnjunctin with the Infrmatin Incident

More information

Phi Kappa Sigma International Fraternity Insurance Billing Methodology

Phi Kappa Sigma International Fraternity Insurance Billing Methodology Phi Kappa Sigma Internatinal Fraternity Insurance Billing Methdlgy The Phi Kappa Sigma Internatinal Fraternity Executive Bard implres each chapter t thrughly review the attached methdlgy and plan nw t

More information

Chapter 7 Business Continuity and Risk Management

Chapter 7 Business Continuity and Risk Management Chapter 7 Business Cntinuity and Risk Management Sectin 01 Business Cntinuity Management 070101 Initiating the Business Cntinuity Plan (BCP) Purpse: T establish the apprpriate level f business cntinuity

More information

Directors' And Officers' Liability

Directors' And Officers' Liability Directrs' And Officers' Liability (Last Revised January, 2005) The fllwing is intended fr general infrmatin nly, regarding sme f the issues relating t purchasing a business in Saskatchewan. We advise yu

More information

Hampton Roads Orthopaedics & Sports Medicine. Notice of Privacy Practices

Hampton Roads Orthopaedics & Sports Medicine. Notice of Privacy Practices This is being prvided t yu as a requirement f the privacy regulatins issued under the Health Insurance Prtability and Accuntability Act f 1996 (HIPAA). This ntice describes hw HROSM may use and disclse

More information

The Importance of Market Research

The Importance of Market Research The Imprtance f Market Research 1. What is market research? Successful businesses have extensive knwledge f their custmers and their cmpetitrs. Market research is the prcess f gathering infrmatin which

More information

Spread Bet Terms: Deposit Accounts

Spread Bet Terms: Deposit Accounts Spread Bet Terms: Depsit Accunts 1. Structure 1.1 When we engage in Spread Betting with yu, we d s n the basis f: - ur General Terms; these terms, i.e. ur Spread Terms. 1.2 The Spread Terms deal with matters

More information

University of Texas at Dallas Policy for Accepting Credit Card and Electronic Payments

University of Texas at Dallas Policy for Accepting Credit Card and Electronic Payments University f Texas at Dallas Plicy fr Accepting Credit Card and Electrnic Payments Cntents: Purpse Applicability Plicy Statement Respnsibilities f a Merchant Department Prcess t Becme a Merchant Department

More information

POLISH STANDARDS ON HEALTH AND SAFETY AS A TOOL FOR IMPLEMENTING REQUIREMENTS OF THE EUROPEAN DIRECTIVES INTO THE PRACTICE OF ENTERPRISES

POLISH STANDARDS ON HEALTH AND SAFETY AS A TOOL FOR IMPLEMENTING REQUIREMENTS OF THE EUROPEAN DIRECTIVES INTO THE PRACTICE OF ENTERPRISES POLISH STANDARDS ON HEALTH AND SAFETY AS A TOOL FOR IMPLEMENTING REQUIREMENTS OF THE EUROPEAN DIRECTIVES INTO THE PRACTICE OF ENTERPRISES M. PĘCIŁŁO Central Institute fr Labur Prtectin ul. Czerniakwska

More information

NAIC Replacement Requirements For Certain Life Insurance Policies And Annuity Contracts

NAIC Replacement Requirements For Certain Life Insurance Policies And Annuity Contracts NAIC Replacement Requirements Fr Certain Life Insurance Plicies And Annuity Cntracts Duties f Prducers If a transactin invlves a replacement, the prducer must leave with the applicant, at the time an applicatin

More information

Consumer credit law for Insolvency Practitioners (IPs)

Consumer credit law for Insolvency Practitioners (IPs) Page 1 Cnsumer credit law fr Inslvency Practitiners (IPs) Prduced in partnership with Carline Castle f Squire Pattn Bggs (UK) LLP This Practice Nte prvides a summary f cnsumer credit law fllwing the transfer

More information

RE: Operational Standards for the Cancer Waiting Times Commitments

RE: Operational Standards for the Cancer Waiting Times Commitments 30 July 2009 T: Strategic Health Authrity Chief Executives Primary Care Trust Chief Executives NHS Trust Chief Executives CC: Care Quality Cmmissin Mnitr NHS Imprvement Natinal Cancer Actin Team Strategic

More information

KERRY ROGERS, DIRECTOR OF CORPORATE SERVICES/COMPANY SECRETARY

KERRY ROGERS, DIRECTOR OF CORPORATE SERVICES/COMPANY SECRETARY Bard f Directrs Meeting Reprt Subject: Gvernance Framewrk Date: 30 th Octber 2014 Authr: KERRY ROGERS, DIRECTOR OF CORPORATE SERVICES/COMPANY SECRETARY Lead Directr: KERRY ROGERS BACKGROUND A Bard s prpsed

More information

DRUG, ALCOHOL AND SUBSTANCE MISUSE POLICY FOR THE WORKPLACE

DRUG, ALCOHOL AND SUBSTANCE MISUSE POLICY FOR THE WORKPLACE DRUG, ALCOHOL AND SUBSTANCE MISUSE POLICY FOR THE WORKPLACE Intrductin Write yur business name here recgnises that drug, alchl and substance misuse are grwing scial and medical prblems, which can lead

More information

Internet and E-Mail Policy User s Guide

Internet and E-Mail Policy User s Guide Internet and E-Mail Plicy User s Guide Versin 2.2 supprting partnership in mental health Internet and E-Mail Plicy User s Guide Ver. 2.2-1/5 Intrductin Health and Scial Care requires a great deal f cmmunicatin

More information

Abuse of Metropolitan Police issued AMEX cards

Abuse of Metropolitan Police issued AMEX cards Abuse f Metrplitan Plice issued cards Managed Investigatin Cmmissiner's Reprt IPCC Cmmissiner s Reprt Intrductin This reprt prvides an verview f investigatins int the use f American Express crprate credit

More information

How ISO 9001 and Support Sarbanes-Oxley Compliance. By Sandford Liebesman

How ISO 9001 and Support Sarbanes-Oxley Compliance. By Sandford Liebesman Change Management Cnsulting, Inc. Transfrming Businesses Wrldwide Hw ISO 9001 and 14001 Supprt Sarbanes-Oxley Cmpliance By Sandfrd Liebesman Intrductin In September 2005, I published an article in Quality

More information

Financial Accountability Handbook

Financial Accountability Handbook Financial Accuntability Handbk >> Vlume 5 Reprting Systems Infrmatin Sheet 5.2 Preparatin f Financial Statements Intrductin The Financial Accuntability Act 2009 (the Act) and the Financial and Perfrmance

More information

Médecins Sans Frontières Australia Job Description

Médecins Sans Frontières Australia Job Description Médecins Sans Frntières Australia Jb Descriptin POSITION DESCRIPTION Psitin Lcatin: Reprting t: Supervising: Status: Service Centre Technical Crdinatr Sydney (Bradway) Service Centre Manager N/A 6-mnths

More information

WHAT YOU NEED TO KNOW ABOUT. Protecting your Privacy

WHAT YOU NEED TO KNOW ABOUT. Protecting your Privacy WHAT YOU NEED TO KNOW ABOUT Prtecting yur Privacy YOUR PRIVACY IS OUR PRIORITY Credit unins have a histry f respecting the privacy f ur members and custmers. Yur Bard f Directrs has adpted the Credit Unin

More information

The chief executive officer and the chief finance officer are ex-officio members of the board.

The chief executive officer and the chief finance officer are ex-officio members of the board. DATATEC LIMITED BOARD CHARTER / TERMS OF REFERENCE 1. CONSTITUTION The primary bjective f the Cmpany s Bard Charter is t set ut the rle and respnsibilities f the Bard f Directrs ( the Bard ) as well as

More information

Outsourcing arrangements

Outsourcing arrangements Rules Ntice Guidance Nte Dealer Member Rules Please distribute internally t: Internal Audit Legal and Cmpliance Operatins Regulatry Accunting Senir Management Cntacts: Luis Piergeti Vice President, Financial

More information

The Importance Advanced Data Collection System Maintenance. Berry Drijsen Global Service Business Manager. knowledge to shape your future

The Importance Advanced Data Collection System Maintenance. Berry Drijsen Global Service Business Manager. knowledge to shape your future The Imprtance Advanced Data Cllectin System Maintenance Berry Drijsen Glbal Service Business Manager WHITE PAPER knwledge t shape yur future The Imprtance Advanced Data Cllectin System Maintenance Cntents

More information

Spread Bet Terms: Deposit Accounts

Spread Bet Terms: Deposit Accounts Spread Bet Terms: Depsit Accunts 1. Structure 1.1 When we engage in Spread Betting with yu, we d s n the basis f: - ur General Terms; these terms, i.e. ur Spread Terms. 1.2 The Spread Terms deal with matters

More information

Commission for Ethical Standards in Public Life in Scotland

Commission for Ethical Standards in Public Life in Scotland Cmmissin fr Ethical Standards in Public Life in Sctland REPORT TO PARLIAMENT Laid befre the Scttish Parliament by the Public Appintments Cmmissiner fr Sctland in pursuance f Sectin 2(8) a f the Public

More information

FORM ADV (Paper Version) UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT FORM BY EXEMPT REPORTING ADVISERS

FORM ADV (Paper Version) UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT FORM BY EXEMPT REPORTING ADVISERS APPENDIX A FORM ADV (Paper Versin) UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT FORM BY EXEMPT REPORTING ADVISERS Frm ADV: General Instructins Read these instructins carefully befre

More information

Plus500CY Ltd. Statement on Privacy and Cookie Policy

Plus500CY Ltd. Statement on Privacy and Cookie Policy Plus500CY Ltd. Statement n Privacy and Ckie Plicy Statement n Privacy and Ckie Plicy This website is perated by Plus500CY Ltd. ("we, us r ur"). It is ur plicy t respect the cnfidentiality f infrmatin and

More information

First Global Data Corp.

First Global Data Corp. First Glbal Data Crp. Privacy Plicy As f February 23, 2015 Ding business with First Glbal Data Crp. ("First Glbal", First Glbal Mney, "we" r "us", which includes First Glbal Data Crp. s subsidiary, First

More information

GUIDANCE FOR BUSINESS ASSOCIATES

GUIDANCE FOR BUSINESS ASSOCIATES GUIDANCE FOR BUSINESS ASSOCIATES This Guidance fr Business Assciates dcument is intended t verview UPMCs expectatins, as well as t prvide additinal resurces and infrmatin, t UPMC s HIPAA business assciates.

More information