Expert answer:please see below and attached

Expert answer:Please address each question separately with a sub-heading for Clarity. Paper has 4 sections: Please include references in each section. 1 section is a power point with its instructions. On the word documents, at least 2 pages each with references.
final_project_assignment.pdf

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MJD 725/LAWD 6159
Fall 2017
FINAL CLASS PROJECT
➢ Assignment is due no later than Monday, December 11, 2017, 11:59 p.m.
➢ All supporting documents, references and examples are included in the Week 16 Class
Tab.
➢ Office hours will be held on November 30 for anyone who has questions regarding the
assignment.
➢ Please label each of your documents last name first, then document type. (Examples:
Smith Code of Conduct; Smith Antibribery Slides; Smith Investigation Prep; Smith
Memo to President)
➢ All final project assignments must be submitted via the final project drop box.
PART ONE (80 points of your final project grade)
Congratulations, you have been hired as the Chief Compliance Officer for the SAC Corporation (“SAC” or
“Company”), a U.S. based holding company with global interests in the areas of skin and health care
products, clothing, pharmaceuticals, energy, and petroleum, with its own non-profit charitable
organization and lobbying group/PAC. A department of one, understaffed and under resourced, you
have been with the Company for three days. To make things a bit more challenging, you have been
notified by your legal department that your Company is being served with a subpoena from the United
States Department of Justice, regarding allegations of violations of the Foreign Corrupt Practices Act
(“FCPA”) in relation to one of the Company’s sales departments and government officials of Saudi
Arabia.
Because it is unclear which wholly owned subsidiary of SAC is responsible for the alleged FCPA
violations, you may choose to focus your efforts on just one of the entities most in line with your real life
experiences or interests, or draft an enterprise wide solution.
Your company’s President (President Green) has just informed you of his concerns and the magnitude of
the problem facing the Company. First, your Company has no code of conduct policy (only a single page
document that states the Company’s corporate values). Second, your Company never trained any
employees on the FCPA or any other anti-bribery regulation. Third, the Company does not have a
records management policy, only a schedule that lists retention dates. Fourth, the Company does not
know where to start with the investigation, especially since its legal department has never dealt with a
matter such as this. And finally, the Company needs your expertise on how to plan out the investigation
and response to the government regarding SAC’s corporate culture.
Your solution (final project documents to submit) must include:
1. For 40 points of your final project grade: A draft Code of Business Conduct policy (which
includes an anti-bribery policy that includes at the least the FCPA requirements and the UK AntiBribery Act). (See examples in Week 16 navigation tab.) Your draft must be grammatically
correct and organized, and must include, at a minimum, sections regarding anti-bribery, gifts
and gratuities, business entertainment, conflicts of interest, and the Company’s zero tolerance
for retaliation.
2. For 20 points of your final project grade: A training presentation on anti-bribery compliance to
be done in person (A minimum of five slides in either PowerPoint or Microsoft Word, and a
maximum of 15 slides). This should include references to the applicable regulations, but
primarily focus on hypotheticals for spotting issues, communication paths, and how to report
allegations or inquiries regarding potential bribery situations. It should also have at least one
reference to the Company’s Anti-Retaliation Policy.
3. For 20 points of your final project grade: A summary of the issues and investigation
preparation plan for record, addressed to the Vice President of Legal/General Counsel to keep
the legal department abreast of what departments and individuals need to be involved in the
investigation, as well as what laws and policies need to be reviewed for potential violations.
(Similar to what you produced with the Investigation Preparation Assignment, taking into
account the Professor’s comments and suggestions from that assignment).
PART TWO (20 points of your final project grade)
The following memo must include a minimum of 800 words, double spaced.
A memo to the President of the company for which you work, based on your classes and discussions
from the MJ/LAWD program at Widener and from the book Giving Voice to Values, addressing:
(1) How do you believe you and the Company for which you work can increase employee ownership of
and accountability for compliance and ethics?
(2) How can you foster a “stand up and take action” approach to living the company’s and individual
employee’s values and policies? (Your memo should go beyond just listing ways to train employees how
to spot issues, and should include ways to empower employees to communicate more and speak-up
regarding compliance and ethics).
Be sure all of your responses are grammatically correct and well organized. Please double space your
documents except for the PowerPoint presentation. Be sure to label each of your documents last name
first, then document type (Examples: Smith Code of Conduct; Smith AntiBribery Slides; Smith
Investigation Prep; Smith Memo to President)
All Final Project assignments must be submitted via the final project drop box, and are due by December
11, 2017, 11:59 p.m.
…
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