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Banesco USA
	Accurate Accounting and Financial Controls	Accounting Irregularities and other Accounting, Internal Accounting Controls or Auditing Matters - Any potential accounting/control/auditing irregularity that may be a violation of law such as Sarbanes-Oxley, or other similar law and/or regulation, in any jurisdiction.
	Business Practices	Business Practices (major deficiencies) Business Practices (policy and/or procedural issues) Securities Valuation
	Client Assets, Records and Reviews	Account and Investment Reviews Client Assets Client Disclosures and Records
	Conflicts of Interest	Business Relationships with Clients, Suppliers and Vendors Conflicts of Interest (between clients, suppliers and vendors, not between employees) Gifts and Entertainment Outside Affiliations (board or officer positions) Outside Employment and Compensation (including ownership in other businesses) Personal Fiduciary Appointments and Bequests Personal Relationships Personal Securities Trading (excludes trading on material, nonpublic information) Relationships with Clients, Suppliers or Vendors
	Doing Business with the Government	Government Contracts (including gifts & entertainment) - Violation of Company Policy and any law and/or regulation, in any jurisdiction, governing doing business with a government entity.
	Fraud and Theft	Bribery or Kickbacks (nongovernmental) Fraud or Illegal Activities Theft
	Human Resources	Abuse of Authority (inappropriate supervisory directions) Alcohol/Drug/Substance Abuse in Workplace Discrimination, Harassment, Equal Employment or Diversity Issues Employee Background Checks Employee Disputes Professional License Retaliation
	Information and Records	Client Information and Data Protection (includes lost or compromised records and privacy matters) Information Systems Intellectual Property/Copyright Issues Proprietary or Confidential Information Records Management and Record Keeping
	Legal and Regulatory Matters	Escheat and Unclaimed Property Fair Competition, Antitrust and Antiboycott Matters Foreign Corrupt Practices Act and Improper Payments Insider Trading Inter-affiliate Agreements/Credit Extensions Money Laundering, Terrorist Financing, Know Your Customer Matters and OFAC
	Media and Company Name	Company Name and Brand Media or Public Relations
	Physical Assets	Physical Assets - Unauthorized, unlawful or improper use of Company assets, including the unauthorized use of assets for other than legitimate business purposes.
	Political Activities	Lobbying Activities Political Activities and Contributions (Personal and Organizational)
	Procurement and Purchasing	Procurement and Purchasing Practices - Refers to any violation of Corporate Policy governing procurement and purchasing practices.
	Safety Matters	Physical Threats or Violence Safety
	Sales and Advertising	Sales, Marketing and Advertising Practices - False, misleading or deceptive advertising, sales or promotional materials; deliberate misleading messages, omissions, false claims about the Company's or any competitor products.
	Tax Issues	Tax Issues - Tax related matters that resulted in a compliance breach.
	Other	Failure to Report a Violation of Code, Policy/Procedure, Law or Regulation Other Inquiry