Which of the Following Is Not a Justice Department Factor

Which of the following is not a Justice Department factor for an effective corporate compliance program that can help a company reduce legal problems and punishment when violations occur:

A) when offenses occur, steps taken to respond and to prevent further offenses
B) effective communication of standards and procedures to all employees
C) consistent communication with Justice about program achievements
D) high-level persons in the organization have responsibility to oversee compliance
E) all of the other choices are part of an effective program