As the end of 2020 rolls around, certainly, a year that we will be glad to move forward from, I wanted to recap the Company’s compliance posture for the year. Yes, 2020 brought many changes to PAP, PPI, PFC, and C&S. From a compliance standpoint, these changes were well overdue and necessary.
Business Initiatives. From a business perspective, new processes were developed and introduced for all of our Representatives, Agents, and Consultants that protect PAP from issues related to the Foreign Corrupt Practices Act (FCPA) and possible reputational harm by minimizing the risk of associating with persons with a bad reputation. These processes translate into new requirements that our representatives, agents, and consultants, must undergo – including signing new Representations and Warranties and training. All these efforts are now consolidated through our Ethics Page found as a link on all Company web sites, title Ethics, and Training.
Physical Security. All employees have been impacted by one or more of the physical security enhancements we now have in place. We have all seen or been a part of the Company’s transformation into security – from electronic access door and badges to the PAP Visitor Access system. All of these enhancements have been carefully identified and implemented in a manner that supports the Company’s efforts to keep all employees and our assets secure and ensure proper access and accountability is present for all visitors.
Our new Visitor Access system is now centralized, keeping detailed and searchable records of all that visits to our facilities and automatically performing a search of all visitors using the Bureau of Industry and Security (BIS) Consolidated Search List (CSL). The CSL is a consolidation of the “lists of the Departments of Commerce, State, and the Treasury into a single data feed [used in our Visitor Registration system] as an aid to industry in conducting electronic screens of potential parties to regulated transactions.” The CSL provides the Compliance Office with a starting point in identifying a matched party before an “export” occurs, either verbally, through data, visual, etc. The use of the CSL is strictly to identify the possible need for an export license or follow export license requirements.
Since the inception of the eBadge at PAP, we have seen nearly 110,000 access requests at the many doors that now have access controls. We have almost 200 active access badges and can now terminate access in seconds if necessary. Other new features included the granting of access remotely and immediate notification of any specific access breach attempt. These are 180-degree changes, which are all active and functioning.
PAP Centralized Camera System. All PAP Security cameras were installed, facing doors and other building access points throughout all facilities. The intent of the cameras is security. This is why the cameras only face doors and access points.
Company Policies. Several company policies have been re-written or are new. These include an enhanced Ethics Policy, a new Physical Security Policy, and a Visitor Access Policy, just to name a few.
Conclusion. We have come a long way in 2020, overcoming many obstacles and challenges, not only individually but also as a Company. Compliance will continue to refine our Security processes and institute new procedures and policies that not only protect our Company but enhance the security of our employees and build value.
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