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SEC filings
20-F
BIOLINERX LTD. filed this Form 20-F on 03/10/2016
Entire Document
 
39

 
 
8.
Sanctions in events of violation and failure to report
 
As mentioned above, one of the functions of an enforcement plan is to encourage an organizational culture of compliance with, and respect for, the law. The ISA Document makes clear that “a culture of compliance means that the corporation is obligated to prevent violations of the law and to handle violations and violating parties with the appropriate measures.”
 
8.1
Determination of sanctions in events of violation
 
In view of the ISA determination that “the Company shall institute suitable measures against violating parties, including, in appropriate cases, disciplinary action in respect of anyone violating the provisions of the securities laws or the provisions of the enforcement plan”, the Company shall set forth in each procedure separately, insofar as necessary, the disciplinary action that is required.
 
9.
Findings of a mapping of the existing situation
 
Pursuant to Chapter 7 in the ISA Document: “Adjustment of the plan to the corporation and the unique circumstances thereof, after the performance of a compliance survey in the area of the securities laws”.
 
A summary of the first survey that was performed by Deloitte – Brightman Almagor Zohar, the Company’s consultants for the enforcement plan project, is available in the Officer’s files.
 
10.
Relevant procedures
 
Pursuant to the compliance survey, the Company has formulated the internal procedures that are specified below, while considering the Company’s structure, its unique features, and the potential risks and deficiencies in the area of the compliance with the securities laws to which it is exposed. The role of the procedures is to regulate and determine rules of activity and conduct, the purpose of which is to prevent violations of securities laws as well as to create work processes which will address and control such processes.
 
10.1
Statement of Company Policy – Securities Trades by BioLineRx Ltd. personnel
 
The draft procedure was approved by the Board of Directors on May 15, 2012. The procedure in its final form was approved by the Company’s management on June 6, 2012. The Chief Financial and Operating Officer was appointed as the officer responsible for the procedure.
 
The procedure is relevant to all of the Company’s employees and to those who come into contact with information which may constitute inside information.
 
10.2
Transactions involving interested and related parties
 
The procedure was approved for the first time in December 2010. An amendment to the procedure was approved by the Company’s management on July 3, 2012 and by the Audit Committee and Board of Directors in November 2012.
 
The Executive Director of Finance and Reporting and the General Counsel were appointed as the officers responsible for the procedure.
 
The procedure is mainly relevant to directors, other officers, the finance department and the General Counsel.
 
10.3
Procedure for prospectus/annual report/other reports to the SEC and ISA (Disclosure Controls)
 
The procedure was approved by Company management in September 2012 and by the Audit Committee and Board of Directors in November 2012.
 
The Chief Financial and Operating Officer and the General Counsel were appointed as the officers responsible for the procedure.
 
The procedure is relevant primarily to the Finance Department and the General Counsel
 
10.4
Period end closing procedure
 
(in progress)
 
Approved on ____________
 
Appointed as procedure officer: Manager of Reporting and Control
 
The procedure is relevant to the Chief Financial and Operating Officer and the Finance Department