The FSGO are principles-based and provide for flexibility in establishing and implementing an ethics and compliance program--there is no one-size-fits-all.
A company must meet several requirements to have a 'minimally" effective ethics and compliance program under the FSGO.
Consistent with the intent of the NYSE rules and FSGO to provide flexibility to individual companies in designing and implementing codes of ethics and ethics and compliance programs, codes and related programs come in many shapes and sizes.
Each of the seven FSGO guidelines is very broad in nature.
FSGO 1 indicates that organizations need standards and procedures that will prevent and detect criminal conduct.
FSGO 2 states that high-level personnel must ensure that the organization has an effective compliance and ethics program.
Penalties under FSGO include monetary fines and organizational probation.
If an organization is sentenced under FSGO, calculating its fine can best be described as a three-step process.
the amount from a table in FSGO to which a judge refers.
includes allies of President Benigno Aquino III in the likes of Carina Constantino David, Wigberto Tanada and Edilberto de Jesus.
The FSGO said the use of fake nongovernment organizations (NGOs) in disposing of the pork barrel should not have escaped the lawmakers' attention.
The FSGO also called on President Aquino to form a special committee that would review the PDAF process and recommend safeguards to prevent the misuse of the pork barrel.