COMPLIANCE AND ETHICS OORDINATION AND … · International Compliance and Ethics Coordination and Maximization ... Luis Machado, Wm. Wrigley Jr. Company Luis Ortega, Deloitte Financial

©2007 Foley & Lardner LLP

INTERNATIONAL COMPLIANCE AND ETHICS - 10:00 AM COORDINATION AND MAXIMIZATION

Walker Allen, Elementis Worldwide Inc.

Deidra Gold, Wolters Kluwer North America

Bobbie Gregg, Aon Corporation

John Landis, Foley & Lardner LLP

Paul Liebenson, Tellabs, Inc.

Luis F. Machado, Wm. Wrigley Jr. Company

Luis Ortega, Deloitte Financial Advisory Services LLP


WALKER ALLEN VICE-PRESIDENT, SECRETARY, AND GENERAL COUNSEL ELEMENTIS WORLDWIDE INC.

Walker Allen is Vice President, Secretary and General Counsel of Elementis Worldwide Inc. In this role Mr. Allen has global responsibility for the legal affairs of Elementis plc, a London Stock Exchange listed specialty chemicals company with 1,700 people at over 20 sites worldwide. The operational headquarters of Elementis are in the United States.

Prior to joining Elementis in 1999, Mr. Allen was Associate General Counsel with GE Capital and prior to that Senior Business Counsel with General Electric Company. Before joining GE he was an associate in the corporate departments of Finley, Kumble, Wagner and then Carter, Ledyard & Milburn in New York City.

Mr. Allen received his LLM from New York University School of Law, his JD from Ohio State University College of Law, and his BA from the University of Puget Sound. He is admitted to practice in the State of New York and is a member of the Association of the Bar of the City of New York, the American Bar Association, the International Bar Association and the Association of Corporate Counsel.


DEIDRA GOLD EXECUTIVE VICE-PRESIDENT &

GENERAL COUNSEL WOLTERS KLUWER NORTH

AMERICA

Deidra D. Gold is the Executive Vice President and General Counsel, North American Shared Services, for Wolters Kluwer. Headquartered in Amsterdam, Wolters Kluwer is a leading publisher and provider of information products, software and services, with 2005 annual revenues of U.S. $4.0 billion, a worldwide workforce of more than 18,500 people and operations across Europe, North America and Asia Pacific. The Company's well-known brands include: (i) CCH Incorporated, CT Corporation, Aspen Publishers, TyMetrix, Summation, VMP Mortgage and Bankers Systems in the tax, accounting, corporate, legal and financial services sectors, and (ii) Lippincott, Williams & Wilkins, Ovid Technologies, Facts & Comparisons and Medi-Span in the health sector.

Before joining Wolters Kluwer, Deidra Gold served as an executive officer of a number of public companies and as a partner in two law firms. Beginning in late 2001, Deidra was the Senior Vice President, General Counsel and Secretary of United Stationers Inc., a Nasdaq Fortune 500 wholesale distributor of office, technology and other business products. From 2000 through most of 2001, Deidra was the Vice President and General Counsel of eLoyalty Corporation, a newly formed public IT/CRM services and solutions company.

In early 1998, Deidra joined Ameritech Corporation, formerly a Chicago-based, NYSE-traded communications company, as its Corporate Secretary and a senior securities law/M&A counsel. She also spent much of her tenure assisting with various corporate, securities law and compensation/benefit issues involved in Ameritech's late 1999 acquisition by SBC Communications. Prior to joining Ameritech, Deidra served as a principal (partner) in the Chicago law firm of Goldberg, Kohn, Bell, Black, Rosenbloom & Moritz, Ltd.

Deidra has a bachelor's degree from Wellesley College, a J.D. from Columbia University School of Law and an M.B.A. from the J.L. Kellogg Graduate School of Management at Northwestern University. She is admitted to the Illinois, New York and Ohio State Bars.


BOBBIE GREGG VICE-PRESIDENT AND GLOBAL

CHIEF COMPLIANCE OFFICER AON CORPORATION

Bobbie Gregg joined Aon Corporation in September 2005 as vice president and global chief compliance officer, reporting to Cameron Findlay, executive vice president and general counsel. Ms. Gregg oversees compliance with the requirements of the Aon Regulatory Settlement Agreement with the Attorneys General and Departments of Insurance of the states of New York, Illinois, and Connecticut. She also heads the global compliance function, with responsibility for compliance risk management and global business conduct.

Prior to joining Aon, Ms. Gregg managed the regulatory compliance operations for Bank One, which merged with JP Morgan in 2004. After the merger, Ms. Gregg was the head of compliance for consumer banking and brokerage for the combined firm.

Before joining Bank One, Ms. Gregg was employed by Sears, Roebuck and Co., where she held a number of different positions, including deputy general counsel. Ms. Gregg also served as the first chief compliance officer of Sears, reporting to the chief executive officer and to the Audit Committee of the Board of Directors.

Before joining Sears, Ms. Gregg was in the law department of the City of Chicago. From 1986 to 1988, she was an assistant United States attorney in the Northern District of Illinois, serving in the Criminal Division. From 1984 to 1986, Ms. Gregg was in the law department of Kraft, Inc. and, before joining Kraft, was an associate with the law firm of Rothschild, Barry & Myers in Chicago. Ms. Gregg began her career as a judicial law clerk for federal judge William J. Bauer of the Seventh Circuit Court of Appeals.

Ms. Gregg earned a juris doctor, cum laude, from Northwestern University School of Law, where she served a one-year term as the editor-in-chief of the Journal of Criminal Law and Criminology. She earned a B.A. from the University of Illinois.


JOHN R. LANDIS PARTNER FOLEY & LARDNER LLP

John R. Landis is a partner with Foley & Lardner LLP, and is a member of the firm's Securities Litigation, Enforcement and Regulation Practice. Mr. Landis’ practice includes advising and representing his clients in securities regulatory and enforcement proceedings, internal corporate investigations, commercial litigation and dispute resolution and general business matters (including corporate governance). Mr. Landis’ clients include a number of Fortune 500 corporations, investment banking and municipal finance firms, broker/dealers, mutual funds, hedge funds, insurance companies and banks. Mr. Landis also works with a number of civic and non-profit organizations, including the Kohl Children’s Museum of Greater Chicago.

Prior to joining Foley, Mr. Landis practiced for three years with Cravath, Swaine & Moore in New York City. He graduated from the University of Minnesota School of Law (J.D., magna cum laude, 1988), where he was a member of the law review, after which he clerked for two years for the Hon. James M. Rosenbaum, U.S. District Court, District of Minnesota. Mr. Landis also practiced with the Twin Cities firm Maun & Simon.

A native of Appleton, Wis., Mr. Landis received his undergraduate degree in mathematics from Lawrence University in 1984. He is admitted to practice in Illinois, New York, Minnesota, and Oregon.


PAUL LIEBENSON ASSISTANT GENERAL COUNSEL TELLABS, INC.

Paul Liebenson is Assistant General Counsel—Transactions, International and Compliance at Tellabs, Inc., a global telecommunications network equipment provider headquartered in Naperville, Illinois.

Before joining Tellabs, Paul was a vice president in the Law Department at Motorola, where he worked from 1994 through 2001; vice president, general counsel and secretary for Motorola Nortel Communications from 1992 through 1993; a partner of Winston & Strawn, where he practiced corporate law from 1982 to 1992; and Executive Director of the Inter-American Legal Services Association in Washington, D.C., a nonprofit corporation that promoted legal services for low-income groups in Latin America and the Caribbean, from 1979 to 1982.

Paul received a B.A. from Tufts University, an M.A. from The Johns Hopkins School of Advanced International Studies and a J.D. from Georgetown University Law Center.


LUIS MACHADO ASSOCIATE GENERAL

COUNSEL, CORPORATE AND

ASSISTANT SECRETARY WILLIAM WRIGLEY JR. COMPANY

Luis F. Machado is Associate General Counsel – Corporate and Assistant Secretary of the Wm. Wrigley Jr. Company where he is responsible for Securities, Corporate Governance, Finance and Mergers & Acquisitions matters. Before joining Wrigley, he was Senior Counsel at JohnsonDiversey, Inc. in Racine, Wisconsin where he was responsible for Finance, Public Reporting, M&A and managing legal matters relating to Europe, Middle East & Africa and Latin America. Prior to that he was in the Corporate Group at Altheimer & Gray in Chicago. He Graduated Cum Laude from Loyola University School Of Law in Chicago and is admitted to practice in Illinois.


LUIS ORTEGA SENIOR MANAGER, FORENSIC

& DISPUTE SERVICES DELOITTE FINANCIAL

ADVISORY SERVICES LLP

Luis Ortega is a Senior Manager in the Forensic and Investigative Services practice in Chicago. Luis assists in the management and performance of financial/fraud investigations and provides consulting services in the areas of forensic accounting, litigation support, fraud risk management and internal controls for both domestic and international companies.

Luis joined the Chicago office in 2001 after spending nearly four years in Deloitte & Touche’s audit practice in Mexico City. As an independent auditor there, he conducted financial audits for public and private companies of varying sizes and industries, control reviews and regulatory compliance audits. These audit engagements involved the preparation of financial statements and regulatory filings as well as some agreed-upon procedures projects.

Luis received his education at Universidad Iberoamericana, Campus Leon, Mexico: Bachelor of Science in Accounting.


International Compliance and Ethics Coordination and Maximization

National Directors Institute March 8, 2007

1. Panel Introductions

Walker Allen, Elementis Worldwide Inc. Deidra Gold, Wolters Kluwer North American Shared Services Bobbie Gregg, Aon Corporation Paul Liebenson, Tellabs, Inc. Luis Machado, Wm. Wrigley Jr. Company Luis Ortega, Deloitte Financial Advisory Services, LLP John Landis, Foley & Lardner LLP

2. Leadership across borders: Developing an international “Tone at the Top” – Bobbie Gregg

3. “Best Practices” for effectively surmounting communications hurdles

a. Keeping the message, in any language, simple and direct – Luis Machado

b. Handling local business customs or regulations (e.g., privacy concerns) – All

c. Addressing the problem of “Damn Yankees” – All

4. Unique lessons from overseas corporations with a major U.S. presence – Deidre Gold

a. Advising the board and senior management regarding U.S. expectations – Walker Allen

5. Current substantive issues creating new challenges – Paul Liebenson

a. Joint ventures, business partners and affiliates

b. FCPA, AML and export regulations as “best practice” examples – Luis Ortega

c. The remote office: effectively working with the farthest outpost of the company – All

6. Questions, comments and discussion

Deloitte& Touche

n the context of corporate governaante means obeying the law. Ethics is tIs

tent to observe the spirit of the law-in othwords, it is the expressed intent to do wha ,

right. In the wake of recent corporate scandarogram that strongly emphasizes both ethics

rnpliance is good business. In fact, the busicase for such a program is compelli '

The Sarbanes-Oxley Act of 2002, along witrelated mandates by the Securities and Exchanommission and new listing rules instituted by

major stock exchanges, raise the ante for eth' behavior and effective corporate complia-programs. Public companies and their seexecutives and board members may be h

accountable--personally accountable in the •^'.f the executives and board members-not o;for the financial reporting provisions of the n-legislation, but also for the aspects pertaining

ethics and corporate compliance. Convercompanies and their leadership that adhere bto the letter and the s•irit of the law can achi;

ubstantial bene

n interesting landscape is developing with regard toethics and corporate compliance. Public and privatepolicies are being enacted that will force companies andtheir executives to "behave" better. But is compliance withthese policies and related legislation enough? In thecurrent climate, corporate leaders should extend theirefforts-and their ethics-beyond the letter of the law.

In reality, companies that follow both the letter and the spirit of the lawby taking a "values-based" approach to ethics and compliance will have adistinct advantage in the marketplace. Such an approach requires seniorexecutives to understand clearly the culture and compliance controls thatexist at all levels of their organizations. Companies must position ethicsand compliance programs as a responsibility of each employee and arespected part of the company culture, not just a "thou shall not" obligation.Companies' senior executives and board members must adhere to the codeof ethics and compliance policies in the same way that all other employeesmust. Benefits of this approach can indude improvements to a company'smarket performance, brand equity, and shareholder value.

The Risks and Rewards of ComplianceSections of the Sarbanes-Oxley Act are very specific with regard to ethicsand compliance.

Section 301 requires the audit committees of public companies to establish"...procedures for the receipt, retention, and treatment of complaints receivedby the issuer regarding accounting, internal accounting controls, or auditingmatters, as well as the confidential and anonymous submission by employeesof the issuer of concerns regarding questionable accounting or auditing matters."

Section 406 requires public companies to institute a code of ethics forsenior financial officers to promote "honest and ethical conduct, includingthe ethical handling of actual or apparent conflicts of interest betweenpersonal and professional relationships...full, fair, accurate, timely, andunderstandable disdosure...and compliance with applicable governmental rulesand regulations."

Section 806 requires "whistleblower protection for employees of publiclytraded companies...No company..., or any officer, employee, contractor,sub-contractor, or agent of such company may discharge, demote, suspend,threaten, harass, or in any other manner discriminate against an employeein the terms and conditions of employment because of any lawful act doneby the employee to provide information, cause information to be provided,or otherwise assist in an investigation regarding any conduct which theemployee reasonably believes constitutes a violation...of any rule orregulation of the SEC, or any provision of Federal law relating to fraudagainst shareholders."

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Compliance with these new requirements canproduce positive results at several levels:

Companies that embed positive ethics deep withintheir culture often enjoy healthy returns throughemployee and customer loyalty and public respectfor their brand, both of which can translate intostronger market capitalization and shareholderreturns.

Companies that go the extra mile with their ethicsand compliance programs also lay the foundationfor the control environment referred to in the newlaws and rules relating to internal controls.

- Company officials who observe the law are morelikely to avoid stiff personal penalties, bothmonetary and potential jail time.

- Since 1991, companies that create, communicate,enforce, and promote effective complianceprograms, as defined by the U.S. FederalSentencing Guidelines for Organizations, havebeen given favorable treatment by the Departmentof Justice, even when misconduct by employees intheir organizations has been proven. The resultantsavings, in terms of mitigated fines, has totaledhundreds of millions of dollars.

Clearly, the benefits of implementing and maintainingan effective ethics and compliance program faroutweigh its costs. When it comes to advice concerningdesign and implementation of these programs, theclear leader is Deloitte & Touche. We offer overa decade of success in consulting with our clients onethics and compliance programs, reinforced by morethan 100 years of helping clients manage risk anduncertainty. Deloitte & Touche has the people,processes, and resources to help your organizationnavigate today's challenging landscape.

How We Can Add Value to Your OrganizationEthics and corporate compliance issues, of course,are nothing new. Regulated industries have facedsuch issues for many years. The U.S. FederalSentencing Guidelines for Organizations institutedin 1991, the False Claims Act of 1986, the watershed

decision in 1996 by the Delaware Chancery Courtregarding Caremark International, Inc., and nowthe Sarbanes-Oxley Act-the United States has awell-established history of legislation and regulationsaimed at protecting shareholders and otherstakeholders from corporate misconduct.Additionally, Internal Control-Integrated

Framework, a report issued by the Committeeof Sponsoring Organizations of the TreadwayCommission (COSO) in 1992, also recognized anorganization's ethics and compliance program as acritical element of a good control environment.

Elements of an EffectiveCompliance Program

The U.S. Federal Sentencing Guidelines for

Organizations provide a clear framework for

corporate compliance programs. Key ele-

ments of a program should include:

Standards and procedures to prevent

criminal conduct

Oversight by high-level person(s)

(e.g., Chief Compliance Officer)

Care in delegation of substantial

discretionary authority to individuals

(e.g., background checks)

Effective communication of standards

and procedures

Reasonable steps taken to achieve

compliance (e.g., reporting systems, help

line)

Consistent enforcement of

disciplinary mechanisms

Appropriate response after detection of

an offense

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Also well-established is the Ethics and CorporateCompliance Services practice of Deloitte & Touche.Instituted in 1992, ours was the first dedicatedpractice of its type among major public accountingfirms. Our practitioners include attorneys, CPAs, andformer corporate compliance officers. We are focusedintently on helping our clients design, implement,and improve their ethics and compliance programs.And ours is a proven track record of success inhelping leading corporations deal with theseimportant issues.

Our approach reflects the balance and diversity of ourpractitioners. A code of ethics-and thus compliance-must be universal. What is appropriate for theorganization as a whole applies to all individuals. Anorganizations code of ethics must not be waived forselected executives or board members.

Beyond the pure compliance aspects of yourprogram, we can help your organization identify,understand, and live within the standards of behaviorthat are most appropriate for your business and yourindustry. Whether your organization already has anethics and compliance program in place, is seekingto establish one for the first time, or falls somewherein between, we can help.

The Cultural Assessment-a Critical First StepOne of the biggest risk factors for companies todayrevolves around culture. If employees, the eyesand ears of the company, are afraid to raise issuesor challenge management, the company is doomed.

Ethics andCorporate ComplianceIs an Ongoing Process

Even established programs can benefit froma periodic review. Issues raised through an

organization's program and regulatory and/orbusiness changes should be considered to identify

any necessary improvements to the program.

If management doesnot listen to employees,they place themselves atgrave risk.

z Do rank-and-fileemployees understand the tone set by senior man-agement?

n Do you know, without a doubt, that yourorganizations culture encourages ethical behaviorat all levels?

Can employees throughout your organizationdescribe the company's code of ethics?

Do employees in all areas of your organization askquestions and express concerns?

Do your employees believe that the mechanismsare in place to allow them to voice opinionswithout fear of retribution?

A cultural assessment is the first step in answeringthese and other critical questions. The benchmarksthat result from the assessment process become thefoundation for an ethics and compliance program,as well as a solid control environment, which canwithstand scrutiny and propel your company to newheights of success.

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The Board's GrowingResponsibilitiesIn the new and quicklyevolving environment,the board of directorsmust play an increasingly

visible role in overseeing ethics and corporatecompliance. Their involvement is particularlyimportant when it comes to whistleblowers or anyother employee who voices concerns about companyor individual actions.

New regulations require the board to be more activelyengaged in the compliance reporting process. We canhelp the board ask critical questions that go a longway toward fulfilling their oversight responsibilities.Some of these questions might include:

Is there a process for management and the boardto address issues that arise from any level of theorganization?

Does an effective-i.e., utilized-reportingmechanism exist?

Is management willing to take action on reports?

Are employee surveys conducted to determineawareness of and willingness to participate in theethics and compliance program?

What is the culture and "tone at the top" regardingethics? Is the employee's view of the tone inalignment with senior management's?

Is the reward system aligned with the ethics andcompliance program objectives?

The answers to these and other questions can raisethe board's awareness of the alignment between thecompany's intent to comply with its code of ethicsand applicable laws and the company's practices.Such awareness and understanding can significantlyreduce the company's and its board's exposure togovernment actions and stockholder litigation.

Beyond the Legalities-the Advantagesof a Values-Based ApproachGive the average employee a legalistic "thou shallnot..." code of ethics document, and a negativeresponse is almost guaranteed. Give employees adocument that states clearly and concisely thecompany's expectations, outlines acceptablebehaviors, and presents viable options for askingquestions and voicing concerns, and the likelihoodis much greater that they will meet those expectationsand exhibit the desired behaviors. Make the contentsof that document equally applicable to everyone inthe organization-at all levels-and you have the keyingredient for a code of ethics that becomes cultural,with all of the benefits that come with it.

Our approach to ethics and corporate compliance canhelp you construct a platform for responding tochange throughout your organization. It can help youopen new lines of communication that producerewards far in excess of those directly associated withcompliance. We can help your business reduce therisk of exposure, along with the resulting legal costs,officer and director liability, and costly loss ofreputation or brand.

Take advantage of best practices that can reinforceand extend the value of your ethics and complianceprogram. Know that the mechanisms are in place toprovide early warning of deviations from guidelinesand regulations. Create or expand a culture of trust,enthusiasm, and integrity-critical attributes that canproduce measurable results in terms of productivity,employee satisfaction, customer satisfaction, and,

ultimately, brand equity.

Deloitte & Touche can show you how to leverage yourethics and compliance program to the benefit of theorganization as a whole and shareholders specifically.Discover why so many leading companies considerDeloitte & Touche their trusted advisor.

For more information, visit us atwUwdeloitteCOIFlit01 pgOV

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Five-Phase ApproachOur five-phase approach for assisting you in creating or enhancing an ethicsand compliance program may encompass the following activities.

Phase OneRisk/cultural assessment

Through employee surveys, interviews, and document reviews, we can help youvalidate your culture of ethics and compliance at all levels of the organization orestablish a baseline for change. Our report and recommendations will detailobservations and identify gaps between your current practices and benchmarksas outlined in the U.S. Federal Sentencing Guidelines for Organizations framework,the Sarbanes-Oxley Act, SEC and the major stock exchange rules, and otherapplicable laws and regulations. From these assessments will emerge a detailedwork plan.

Phase TwoProgram design/update

In this phase, we help you create guideline documents that outline the reportingstructure, communications methods, and other key components of the code ofethics and compliance program.This encompasses all aspects of the program,fromgrass roots policies to structuring board committees that oversee the program;from establishing the mandatory anonymous complaint reporting mechanism-i.e., compliance and ethics help line or whistleblower hot line-to spelling out thespecifics of the code of ethics in a way that is easily understood by everyone at alllevels of your organization.

Phase ThreePolicies and procedures

We help you develop or enhance the detailed policies of the program, includingissues of financial reporting, antitrust, conflicts of interest, gifts and entertainment,records accuracy and retention, employment, the environment, global business,fraud, OSHA, political activities, securities, and sexual harassment, among others.

Phase FourCommunication, training, and implementation

Even the best policies and procedures are useless if they are not institutionalized-they must become part of the fabric of your organization. We can help you clearlyarticulate, communicate, and reinforce not only the specifics of the program, butalso the philosophy behind it, and the day-to-day realities of it.In this way, your keystakeholders and other personnel are more likely to embrace the program andincorporate it into their attitudes and behaviors.

Phase FiveOngoing self-assessment, monitoring, and reporting

The true test of your ethics and compliance program comes over time. How do youknow in one year or five that both the intent and letter of the law are still beingobserved throughout your organization? How does the program-and yourorganization-adapt to changing legislation and business conditions? As yourorganization evolves-for example, through mergers and acquisitions-will theprogram remain relevant? The cultural assessment, mechanisms, and processesthat we help you put in place today, including employee surveys, internal controls,and monitoring and auditing programs, can help you achieve sustained success.

The Role ofTechnologyin Ethics andCompliance

fstatement frauds, as well as

A critical component of aneffective ethics and complianceprogram is the ability to monitorand audit compliance in a "realtime manner." Yet as companiescross geographical and industryboundaries, it is becoming harderto perform this role in thetraditional manner. As a result,companies are increasinglyseeking technology solutionsto help them identify potentialunethical behaviors before thecost becomes too great.

Our Forensic and InvestigativeServices experience allows us toassist companies in investigatingand quantifying the cost offraudulent activity that hasoccurred. This experience isaugmented by state-of-the-art,cutting-edge software toolsthat are deployed through aworldwide network of computerforensic labs. Using proprietarysearch-and-retrieval technologycoupled with powerful data and

n network analysis capabilities,these tools identify and analyzepotential indicators ofmisappropriations and financial

preserve the information asevidence for use in court.

p

4

j

Employing these sophisticatedtechnological tools, our forensicspecialists can assist a companyin proactively detecting unethicalbehavior and help it maintaincompliance with its own policiesand procedures.

"Ethics and Corporate Compliance" is a publication of Deloitte & Touche's CorporateGovernance Services designed to help you clearly understand the fast-evolving requirementsof the new regulatory and stock market rules, while keeping your response aligned withyour broader corporate goats and strategies. These services focus around four specific areas- board roles and responsibilities, ethics and corporate compliance, risk management andcontrols, and transparency and disclosure.

For more information, visit us at www.detoitte.corn/us/corpgov

About Deloitte & Touche

Deloitte &Touche, one of the nation's leading professional services firms, provides assurance and advisory, tax, andmanagement consulting services through nearly 30,000 people in more than 100 U.S. cities. The firm is dedicated tohelping its clients and its people excel. Known as an employer of choice for innovative human resources programs,Deloitte & Touche has been recognized as one of the "100 Best Companies to Work For in America" by Fortune magazinefor six consecutive years. Deloitte & Touche is the U.S. national practice of Deloitte Touche Tohmatsu. Deloitte ToucheTohmatsu is a Swiss Verein, and each of its national practices is a separate and independent legal entity. For moreinformation, please visit Deloitte & Touche's Web site at wwwdeloitte.c on.

This publication contains general information only and should not be relied upon for accounting, business, financial,investment, legal, tax, or other professional advice or services. This publication is not a substitute for such professionaladvice or services, nor should it be used as a basis for any decision or action that may affect you or your business. Beforemaking any decision or taking any action that may affect you or your business, you should consult a qualified professionaladvisor. The information contained in this publication likely will change in material respects; we are under no obligation toupdate such information.

Neither Deloitte & Touche LLP, Deloitte Touche Tohmatsu nor any of their affiliates or relatedentities shall have any liability to any person or entity who relies on this publication.

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COMPLIANCE AND ETHICS OORDINATION AND … · International Compliance and Ethics Coordination and Maximization ... Luis Machado, Wm. Wrigley Jr. Company Luis Ortega, Deloitte Financial