Supervising the Implementation of Internal Securities Compliance Program in a Government-Owned Utilities Company

Our firm was chosen to supervise the process of effective implementation of the Israel Securities Authority's internal compliance program, which was the first of its kind.

At the conclusion of administrative enforcement proceedings conducted by the Israel Securities Authority against a government-owned utilities company (the “Company”), in connection with a breach of reporting obligations and an administrative enforcement arrangement signed between the Company and the Israel Securities Authority, it was determined that the Company would appoint an external supervisor for the effective implementation of the internal securities compliance program, whose identity would be agreed upon by the Israel Securities Authority. Our firm was chosen to supervise the process, which was the first of its kind. In the framework of serving as supervisor for the implementation of the Company’s internal securities compliance program, our firm examined the compliance program itself as well as its implementation. We thoroughly examined internal documents and procedures at the Company and met with various officers, key employees and members of the Company’s securities compliance team. In addition, our firm participated in certain meetings of the Company’s board of directors and its committees. Our firm submits its findings to the head of the Administrative Compliance Department of the Israel Securities Authority once every quarter.
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