policy/2010/34-61340.pdf. 3° See U.S. SENTENCING GUIDELINES at § 8B2.1(a)(2). 01 US, SENTENCING GUIDELINES § 8B2.1(b). | -NDIX 3° See generally DEBBIE TROKLUS, ET AL., COMPLIANCE 101: How TO BUILD AND MAINTAIN AN EFFECTIVE COMPLIANCE AND ETHICS E n d n ot es PROGRAM, SOCIETY OF CORP. COMPLIANCE AND ETuHICcs (2008) 3-9 [hereinafter COMPLIANCE 101] (listing reasons to implement compliance program, including protecting company’s reputation, creating trust between management and employees, preventing false statements to customers, creating efficiencies and streamlining processes, detecting employee and contractor fraud and abuse, ensuring high- quality products and services, and providing “early warning” system of Executive with FCPA Violations and Investment Adviser Fraud, No. inappropriate actions); TRANSPARENCY INT'L, BUSINESS PRINCIPLES 2012-78 (Apr. 25, 2012) (indicating corporate employer was not charged FOR COUNTERING BRIBERY: SMALL AND MEDIUM ENTERPRISE in the matter and had “cooperated with the SEC’s inquiry and conducted (SME) Epirion 5 (2008) (citing benefits of anti-bribery program a thorough internal investigation to determine the scope of the improper like protecting reputation, creating record of integrity enhances payments and other misconduct involved”), available at hetp:/ /WWw.sec. opportunities to acquire government business, protecting company gov/ news/ press /2012/2012-78.htm. assets otherwise squandered. on bribes); Mark PIETH, HARMONISING 308 See USAM § 9-28.800.B. ANTI-CORRUPTION COMPLIANCE: THE OECD Goon PRACTICE 3 See, e.g., INT'L CHAMBER OF COMMERCE, ICC RULES ON GUIDANCE 45-46 (2011) [hereinafter HARMONISING ANTI- COMBATING CORRUPTION (2011) [hereinafter ICC RULES ON CORRUPTION COMPLIANCE] (citing need for compliance program CoMBATING CorrupTIon |, available at http://www.icewbo. to prevent and detect in-house risks, such as workplace security or org/uploadedFiles /ICC/ policy/business_in_society/ Statements/ conflicts