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The S.E.C. concluded that when Mr. Wyser-Pratte met with corporate executives about governance issues, and in one case agreed to serve on a board, his companies did not have adequate procedures to assure that there was no illegal trading.
"If the city did not have adequate procedures for awarding contracts, he had a duty to announce that for the past eight years," said Mr. Badillo.
Ramping up internal processes over time may be enough to show prosecutors a commitment to implementing adequate procedures for preventing tax evasion.
The reviews also found that most of the health plans lacked adequate procedures for settling disputes with providers.
As such, adequate procedures for informed consent may run counter to companies' business interests.
And there are no common procedures for assuring that patients consent to sharing their information.
It details procedures for assuring that people affected by emergency rules get hearings and lawyers.
These mixed-use facilities are then required to implement procedures for assuring that each category of user only has access to the appropriate program tree.
The interfacial polyaddition technique combined with spontaneous emulsification is an adequate procedure for PU microstructures synthesis.
Speaking for an 8-to-1 majority, Justice Ginsburg said an employer could ordinarily defend itself by showing that it had adequate procedures in place for reporting harassment and the employee had failed to use those procedures.
(5) The process for assuring adequate authority for intergovernmental cooperation in the implementation of the State WQM program.
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Justyna Jupowicz-Kozak
CEO of Professional Science Editing for Scientists @ prosciediting.com