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senasa-spain.bsky.social
✈️ 👥 @senasa-spain.bsky.social participated in #ICASS conference in London to debate about latest developments on #ReportingSystems. Our UNS team presented the integration of #AI into #SNS processes to enhance #OperationalSafety through the information gathered from #Notifications.
October 21, 2025 at 8:59 AM
epsteinweb.bsky.social
Parts 1-4/5 — EFTA01080416.jpg
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Available in the iOS app store now!
https://apps.apple.com/us/app/epstein-web/id6758880661
EFTA01080289 | EFTA01080416 circumstances wee present: (I) a corporation voluntarily and fully disclosed the potential misconduct: (2) corporate principles voluntarily engaged in interviews with DOJ and provided truthful and complete information about their conduct: (3) a parent company conducted extensive prc-acquisition duc diligence ofpotentially liable subsidiaries and engaged in significant re:mediation efforts post-acquisition; (4) a company provided information about its extensive compliance procedures. and internal controls: (5) a company agreed to a civil resolution with the Securities and Exchange Commission while also demonstrating that criminal dcdination was appropriate: (6) only a single employe was involved in the improper payments: and (7) the improper payments involved minimal funds compared to overall business revenues. ".&e CriminaHnformation. tinned.States Sc Peterson. supra note 8. Press Release, US. Dept. ofJusticc. Former Morgan Stanley Managing Director Pleads Guilty for Role in Evading Internal Controls Required by FCPA (Apr. 25, 2012), available as http://www.justicegov/opa/ pr/2012/Apti1/12-erm-534.html ("Aker considering all the available facts and circumstances. including that Morgan Stanley constructed and maintained a system ofinternal controls. which provided reasonable assurances that its employee were not bribing government officials. the Department ofJustice declined to bring any enforcement action against Morgan Stanley related to Peterson's conduct. The company voluntarily disclosed this matter and has cooperated throughout the department's investigation:); see also Press Rekasc. U.S. Sec. and Exchange Comm.. SEC Charges Forma Morgan Stanley Executive with FCPA Violations and Investment Adviser Fraud (Apr. 25. 2012). atuilsblom http://www. sec.govInews/press/2012/2012-78.htm ("Morgan Stanky. which is not charged in the mama. cooperated with the SEC's inquiry and conducted a thorough internal investigation to detaminc the scope of the improper payments and other misconduct involved:). "SEC Rules of Practice. 17 C.F.R. $ 201.102(c). "Deferred Pros. Agreement. In the Matter of Tenaris.S.A. (May 17, 2011).ant/ladle& http://vnrwsce.govinews/press/2011/2011-112-dpa. pdf; see also Press Release. US. Sec. and Exchange Comm..Tenaris to Pay $5.4 Million in SEC's First-Ever Deferred Prosecution Agreement (May 17. 2011).am/tit:kat kup://marocc-gov/news/press/2011/2011-112. htm. "See Non-Pits. Agreement. In re Thetis. S.A. (May 17, 2011).andaHr at http://www.justice.gothriminaVfraudIfcpakaserhenths-sa/201103-14-tenatis.pdf. "Sec U.S. SEC. AND EXCHANGE COMM- ENFORCEMENT MANUAL 6.2-3. (March 9. 2012). smaittbk of http://www•sec-gov/divisions/ enforce/atforcementmanual.pdf. "Seed 6.24. "Steid.4 26. "18 1514A(e). 18 U.S.C. $ 1513(e). "15 U.S.C. 478u-6(a)(3). Thc new provision defines 'original information to mean information that: (A) is derived from the independent knowledge or analysis of a whisdeblowee (B) is not known to the Commission from any other source. unless the whistleblower is the original source of the information: and (C) is not exclusively derived from an allegation made in a judicial or administrative hearing. in agovernmental report. hosing. audit. or investigation. or from the news media. unless the whistkblower is a source ofthe information. "15 U.S.C. $ 78u-6: see also Dodd-Frank Wall Street Reform and Corcoran. Protection Act. Pub. L No.111-203. $ 922.124 Stat 1376. 1841-49(2010). ”' For detailed information about the program. includingeligibility requirements and certain limitations that apply. sec Section 922 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. available at http:/Iwwwscc.govhboutlofficeslowbIdodd-frank-scc-922.01. and the final rules on eligibility. Exchange Act Rule 2IF-8. 17 C.F.R. $ 240.21F-8. "For exampk. the rules: (1) make a whisticblowcr eligible for an award if the whistleblower reports original information internally. and the company informs the SEC about the violations: (2) give whistleblowers 120 days to report information to the SEC afier first reporting internally and still be treated as if he or she had reported to the SEC at the earlier reportingdate . thus preserving their 'place in line" foe a possible whistleblower award from the SEC; and (3) provide that a whisdcblowcr's voluntary participation in an entity's internal compliance and reportingsystems is a factor that can increase the amount of an award and that a whisticblower's interference with internal compliance and reporting system is a factor that can decrease the amount of an award. Ste Exchange Act Ruk 2IF. 17 C.F.R. $ 240.21F. ".Ste Exchange Act Ruk 21F-7(b). 17 C.F.R.$ 240.21F-7(b). "For example. SEC staffwill not disclose a whistleblower's identity in response to requests under the Freedom ofInformation Act. However, that arc limit+ on SEC's ability toshield a whistleblower's identity, and in certain circumstances SEC must disclose it to outside entities. For example. in an administrative or court proceeding. SEC may be required to produce documents or other information that would reveal the whistkbloweri identity. In addition. as part ofongoing SEC investigatory responsibilities. SEC staffmay use information provided by a whisdeblower during the course of the investigation. In appropriate circumstances. SEC may also provide information. subject to confidentiality requirements. to other govanmental or regulatory entities. Exchange Act Rulc 2IF-7(a). 17 C.F.R. 240.21F-7(a). "'Although SEC does not have an opinion procedure release process. it has declared its decision to follow the guidance announced through DOJ's FCPA Opinion Rckase Procedure. US. Sec. and Exchange Comm.. SEC Release No. 34-17099 (Aug. 29. 1980). maiLible at http:// wwwsce.get/nom/digest/1980/dig082980.pdf. SEC Release No. 3417099 sated that. to encourage issuers to take advantage of the DOJ1 FCPA Review Procedure. a+ a matter ofprosecutorial discretion. SEC would 'not take enforcement action alkging violations ofSection 30A in any case where an issuer has sought and obtained an FCPA Review letter from the Department. prior to May 31. 1981. mating that the Department will not take enforcement action under Section 30A with respect to the transaction involved: Id. Thc release funher noted that it would revisit this policy once the DO) had evaluated the results of the FCPA Review Procedure aka its first year of operation. A second release stated that the SEC would continue to adhere to the policy announced in Release No. 34-17099. US. Sec. and Exchange Comm.. SEC Release No. 34-18255 (Nov. 13. 1981). evadable at http://www•.sec.gov/news/ digest/1981/dig111381.pdc. "Both DOJ's opinion procedure releases (from 1993 to present) and review procedure releases (from 1980-1992) are available at http://www. justice.govicriminaVfraud/kpa/opinion. 1'Me full regulations relating to DOJ's opinion procedure arc available at http://www.justice.govicriminaVfraud/fcpa/docs/kperptpdf. 4°128C.F.R.$ 80.1. X0!28 C.F.R.$ 80.3. X0'28 C.F.R.$ 80.12 ("Neither the submission of a request for m FCPA Opinion. its pendency. nor the issuance of an FCPA Opinion. shall in any way alter the responsibility ofan issuer to comply with the accounting requirements of 15 U.S.C. 78m(b)(2) and (3):). °°'28 C.F.R.$ 80.4. 10528 C.F.R.$ 80.5. "28 C.F.R.$ 80.6. 0"•28 C.F.R.$ 80.14(1). This non-disclosure policy applies regardless of whether DO) responds to the request or the party withdraws the request before receiving a rapt:rec. Id. i0t28 C.F.R.$ 80.6. X9"28 C.F.R.$ 80.2. "In connection with any request for an FCPA opinion, DOJ may conduct whatever independent investigation it believes appropriate. 28 C.F.R.$ 80.7. " 28 C.F.R.$ 80.15. Once a request is withdrawn. it has no effect However. DOJ meet; the right to retain a copy ofany FCPA opinion request. documents. and information submitted during the opinion release procedure for any governmental purpose. subject to
May 9, 2026 at 12:38 AM
citizenptnewssc.bsky.social
Dorchester 02 is taking a bold step by adding "hazing" to its bullying policy and streamlining reporting methods to ensure every voice is heard.

Learn more here!

#SC #CitizenPortal #BullyingPolicy #ReportingSystems #StudentSafety
Dorchester 02 moves to add 'hazing' to bullying policy, to centralize reporting via Stop It app
District staff told the board they will add the word 'hazing' to the harassment, intimidation and bullying policy, streamline investigation timelines, accept verbal and anonymous reports (including via the Stop It app), and build a centralized tracking system to avoid misclassifying unfounded reports in PowerSchool.
citizenportal.ai
May 21, 2026 at 1:35 PM