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Global Anti-Corruption Compliance Manual
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Introduction
I
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Anti-CorruptionPolicy
II
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
o
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o
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
o
o
o
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o
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
o
o
o
o
o
o
o
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o
o
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Corporate IntegrityDepartment
III
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
o
o
o
o
o
o
o
o
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
oIntroduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
o
o
o
o
o
o
o
o
o
o
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Handling anti-bribery compliance problems &corrective actions
IV
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Under no circumstances must the reporting of any such potential violation or impropriety serve as a basis for retaliation and intimidation against any employee who acted – or made such report – in good faith.
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
o
o
o
o
o
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Training andEducation
V
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Gifts andHospitality
VI
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
o
o
o
o
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
o
o
o
o
o
o
o
o
o
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
o
oIntroduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
o
o
o
o
o
o
o
o
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
o
o
o
o
o
o
o
o
o
o
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
oIntroduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
SocioenvironmentalInvestments
VII
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
o
o
o
o
o
o
*subject to applicable labour laws and the terms of negotiated collective bargaining
rights.
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Suppliers
VIII
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
o
o
o
*Service providers, suppliers of materials or equipment, vendors, agents, distributors,
brokers, consultants, representatives, other contractors or suppliers, and other
intermediaries paid to represent Vale. Supplier does not include customers or recipients of
socioenvironmental investments. Separate rules apply for Government Authorities.
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
o
o
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
*Employees may use a risk classification questionnaire provided by the Corporate Integrity department (e.g., the Initial Risk Assessment Questionnaire) to establish the Supplier's level
of corruption risk, or request the Supplier to complete such questionnaire.
o
o
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
o
o
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Appendices
Joint ventures, consortia, and other associations
IX
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
o
o
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Selection and compensation of employees and managers
X
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Books, records, and financial reporting
XI
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
o
o
o
o
o
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Internal auditing and monitoring
XII
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Appendices
XIII
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
o
o
o
o
o
o
o
o
o
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
o
o
o
o
o
o
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
§
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
§
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
§
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
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