The Corporate Compliance Committee, composed of representatives from various departments and functions, conducts regular meetings to review and address compliance issues, emerging risks, and updates to regulatory requirements. This committee serves as a forum for cross-functional collaboration and knowledge sharing, ensuring that compliance efforts are coordinated and comprehensive across the organization. Internal Audit plays a vital role in independently evaluating the effectiveness of the ethics and compliance program, conducting risk assessments, and providing recommendations for improvement. The Chief Ethics and Compliance Officer also collaborates with external experts, industry associations, and regulatory bodies to stay abreast of best practices and evolving compliance standards. By fostering strong governance, proactive risk assessment, and transparent reporting, Squad demonstrates its commitment to maintaining a robust ethics and compliance program.
The Audit Committee assists the Board of Directors in overseeing the Company’s systems for monitoring compliance with and enforcement of the Company’s Ethics and Compliance Program.
The [Committee] co-chairs and senior members of the team are appointed by the president & COO. The General Counsel, Chief Ethics & Compliance Officer, Corporate Controller, and the managers of Corporate Affairs, Human Resources, and Internal Audit are standing members of the Committee. Each GBU is represented on the [Committee] by a senior member appointed by the GBU President, and approved by the co-chairs. No substitutes are permitted on a short-term or long-term basis.
The Corporate Compliance Committee is responsible for the assessment and prioritization of legal compliance risk areas, the sharing of compliance program best practices, and the development of enterprise-wide tools and monitoring mechanisms to increase the efficiency and effectiveness of company-wide compliance activities.
The Committee’s compliance risk assessment is shared annually with the senior management oversight committee and the Audit Committee of the Board of Directors.
Committee members are legal risk area subject matter experts and senior managers with compliance responsibility for specific risk areas, as well as the managers of Internal Audit, who serve as advisors to the Committee. The members are appointed to the Committee by the Chief Ethics and Compliance Officer, who serves as Chair of the Committee, in consultation with the Senior Compliance Counsel, who serves as Vice Chair. Business-based ethics and compliance officers serve as ex officio members. Members are expected to attend all meetings or designate a substitute.
The Corporate Compliance Committee meets quarterly to review company-wide compliance program activities. Members present progress reports on the status of the compliance efforts for their assigned legal risk areas, whether there have been any changes to the risk area or their evaluation of the level of risk, and any adjustments to the compliance program to address these changes.
As part of the continuous risk assessment process Subject Matter Expert (SME) members provide annual written reports on their assigned compliance risk areas, covering the adequacy of corporate policies, instructions, procedures etc. which define and implement their programs; any significant regulatory, political, or legal changes in their area of responsibility and whether these changes affect the level of compliance risk; and any new compliance risks to the company which need to be addressed.
Business-based ethics and compliance officers provide an annual assessment and supplemental compliance training plan for any additional compliance training needed in their organizations beyond the company-wide compliance training core courses to address business-specific compliance risks, including specialized training required for high-risk employees on an annual basis.
SQUAD’s Internal Audit group provides independent and objective assurance on the effectiveness of internal controls, including those designed to assure compliance with policies, procedures, laws and regulations.
Internal Audit prepares its annual audit plan with a focus on detecting corruption and uses the Transparency International Corruption Perceptions Index as one of the criteria for selecting which projects to audit. It also consults with Compliance counsel on an annual basis to identify emerging areas of anti-corruption risk and adjusts its audit plan accordingly.
Among other things, Internal Audit:
Internal Audit reports detailing anti-corruption risks are reviewed and assessed by senior management, the Chief Ethics and Compliance Officer, and Compliance Counsel and their findings inform policy and/or procedure enhancements and the development of focused training courses.
At periodic intervals, but no less frequently than every two years, Internal Audit evaluates and tests the implementation of the Ethics & Compliance program procedures and controls designed to promote compliance with company policies and legal obligations to ensure the program is consistent with best practice and the business risks facing the company.
ADDRESS: SHAR- E – NAW, HAJI YAQUB SQUARE, KABUL, AFGHANISTAN.
