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Attachment D (text-only Version)

Attachment D


Organizational Chart Under The Litigating States ("LS") Final Judgment

This diagram contains the following boxes:

  • Board of Directors: The bottom left corner of this box is entitled Antitrust Compliance Committee (ACC).
  • CEO
  • General Counsel
  • Office of Legal Compliance (OLC): The bottom left corner of this box is entitled Compliance Officer. This portion of the box contains the following items:
    • Sits administratively in the Office of Legal Compliance, part of the Office of General Counsel
    • Reports to CEO and ACC
    • Duty under Final Judgment for design and supervision of overall compliance
      • Specified duties including assessments, reporting, ensuring remediation, record-keeping, planning & logistics for training
  • LCA Antitrust Group: This box contains the following items:
    • Responsible for administration of compliance programs, including:
      • Training content, legal advice, reviews, development of any remediation, reports, records

The relationships between the boxes are depicted as follows:

  • From Office of Legal Compliance: Arrows point up to the following:
    • Board of Directors/Antitrust Compliance Committee
    • CEO
    • General Counsel
  • From CEO: Arrow points up to Board of Directors/Antitrust Compliance Committee
  • From General Counsel: Arrow points up to CEO
  • From LCA Antitrust Group: Arrow points up to General Counsel
  • Between Office of Legal Compliance and LCA Antitrust Group: A dotted line connects the two boxes.

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Updated August 14, 2015