Information and Communication. Senior management shall ensure that pertinent information is being identified, captured and communicated in an acceptable format and delivered in a timely manner that enables people to carry out their anti-corruption and risk management responsibilities. The said information systems are required to produce reports containing operational, financial, compliance, and enforcement related information that make it possible to run and control the business effectively. Such reporting mechanisms must be available for employees to communicate concerns without fear of retribution or reprisal.

Fraud Prevention Program. Due to the nature and complex character of international securities transactions, the Board and senior management are required to guard HD Faculty™ from individuals that may be, are, or are potentially a party to sophisticated fraudulent schemes. In light of this, senior management is required to have in place from time to time a strong and rigorous enforcement program in respect to international securities laws and fraud prevention. Therefore, the Directors are required to ensure that the Conduct Review Committee, the Compliance Committee, the Risk Management Committee, and other competent specialists are appointed, where deemed fit and proper, and be empowered from time to time with comprehensive investigative and enforcement powers including:

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regulatory and investigative powers to obtain data, information, documents, statements and records from persons involved in the relevant conduct or who may have information relevant to a given inquiry;

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power to seek orders and/or to take other action to ensure compliance with the regulatory, administrative and investigative powers;

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power to impose administrative sanctions and/or to seek orders from courts or tribunals;

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power to initiate or to refer matters for criminal prosecution;

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where enforcement action can be taken, the power to enter into enforceable settlements and to accept binding undertakings.

Notwithstanding, these enforcement powers should not compromise private rights of action.