Table A1

American system versus Israeli system

IS THERE NECESSARILY A REDUCED SENTENCE UPON ADOPTING CODES AND COMPLIANCE PROGRAMSIS THERE CONSIDERATION OF THE CONTENT OF CODES - DOES THE COURT DEMENT
THICK CODES?
IS THERE A MORE SEVERE SENTENCE UPON NOT ADOPTING
COMPLIANCE PROGRAM
DOES THE CODE BASE LIABILITYWHETHER THE CODE GRANTS PROTECTION AGAINST CRIMINAL LIABILITYWHETHER COMPLIANCE PROGRAMS AND CODES
ARE
COMPELLED
American systemYes
There is a reduced sentence upon adopting compliance programs -according to sentencing guidelines
No consideration of content of code /Demanding only compliance programs -Demanding thin codeYes
There is a more severe sentence upon not adopting Compliance Program and code
Yes
Code of conduct could base liability for commitments
breached
No
Not granting protection from liability
Yes
Corporations are compelled to adopt compliance programs and codes in the framework of agreements with the prosecution
Israeli systemNo
Acknowledgment of necessarily reduced sentence
No consideration of content of codeNo
There is not a severe sentence upon not adopting code
Yes
Code of conduct could base liability for commitments breached
No-
Not granting protection from liability
No
There is no possibility of agreements with the prosecution in order to avoid trial

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