The Company believes that an effective compliance program should address five key areas:

1. Company Policies and Compliance

The Company believes it must have strong policies, procedures, and guidelines that protect the interests of consumers and ensure that the Company and its brand affiliates are complying with applicable laws and regulations.

2. Education and Training

The Company believes it is important to provide adequate education and training regarding the Company’s Policies and Procedures, as well as, related laws and regulations. 

3. Monitoring Compliance

The Company believes it is necessary to have an effective program to monitor compliance of its policies and, in turn, provide an easy and effective way for consumers to report concerns and problematic activity to the Company. By doing this, problematic concerns and activities can be promptly investigated and resolved.

4. Education and Disciplinary Actions

An effective compliance program also takes appropriate disciplinary action against distributors who fail to abide by the Company’s Policies and Procedures, or who act in a manner that is harmful to consumers.   

5. Evaluation and Oversight

The Company believes that its compliance program must be supervised by senior level management. There must also be an organized process for reviewing and evaluating the compliance program and making immediate changes, when necessary, to protect consumers.