An enforcement plan is a mechanism to encourage compliance which is binding on all of a company’s employees, managers and officers.
This document is not intended just for display and the familiarity with its content and the implementation hereof are material to the Company.
Therefore, the Company examined various possible mechanisms for the purpose of assimilation of the enforcement plan and the procedures related hereto, and established the selected mechanisms in an assimilation plan that is brought below.
The purpose of the assimilation plan is to promote and ensure the commitment of all of the relevant parties to the plan, their knowledge of the main parts hereof and the actual implementation hereof in all of their activity.
11.2 Presentation of the enforcement plan
After the completion of the enforcement plan and its approval by the relevant bodies, the plan shall be presented to all of the employees and managers at a Company meeting. At such meeting, the CEO of the Company shall present the main parts of the plan, the importance of compliance herewith, the role of the Enforcement Officer and the manner of publication of the plan.
Following the presentation of the plan, the plan and the procedures related hereto shall be posted on the Company’s website (path/link) and be sent via e-mail to the distribution list of all of the Company’s employees and managers.
A printed copy is to be kept at the offices of the Company’s CEO, Enforcement Officer and the Company’s auditor.
The Enforcement Officer shall examine the need for updating the general documents of the Company (like, for example, disciplinary code, the employment agreements, code of conduct, etc., as well as specific related procedures – employee initiation procedure, inside information procedure, etc.) in order that they include a reference to the subject of administrative enforcement.
From the ISA Document:
Measures shall be taken in order to ensure the commitment of all echelons of the corporation to the aforesaid procedures, for example, through the establishment of such commitment in the disciplinary code or employment agreements.
11.3 Implementation and assimilation of the enforcement plan
Publication of the enforcement plan
The enforcement plan shall be published on the Company’s portal/website and distributed via e-mail to all of the Company’s employees.
Following any updates of the enforcement plan, an e-mail shall be sent with a summary of the changes to all of the Company’s employees.
Team/forum of assimilation of the administrative enforcement plan
The steering committee referred to in Section 4.1.2 shall arrange for the implementation of the internal enforcement assimilation plan and the approval of any updates or modifications that will be performed.
Each new employee, upon his or her arrival at the Company and in the context of the employee’s initiation process as conducted by HR, shall be given access to the enforcement plan, be required to read the main parts hereof and sign that he or she has read the plan.
During the first month of his employment, the new employee will be required to participate in training by the Internal Enforcement Officer on the subject of administrative enforcement.