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Violations of this Code or of the employee’s business’ Compliance Policies and Procedures will subject employees, contractors, consultants and agents to disciplinary action. Any Safwan employee, contractor, consultant or agent who fails to report an actual or suspected compliance issue or other inappropriate activity that has been brought to his or her attention may be subject to disciplinary action, including, but not limited to, the following:

Written letter of reprimand;

Monetary penalty;

Suspension; or


All discipline will be subject to Safwan’s discretion; provided, not inconsistent with local laws applied in this regard.


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