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Are Non-U.S. Public Companies required to make Disclosures regarding a Code of Ethics?

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Are Non-U.S. Public Companies required to make Disclosures regarding a Code of Ethics?

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A non-U.S. public company is required to provide the new code of ethics disclosure in its Exchange Act annual report. A non-U.S. public company, however, will not have to provide in a current report “immediate disclosure” of any change to, or waiver from, the company’s code of ethics for its senior financial officers and principal executive officers. Instead, non-US. public companies are required to disclose any such change or waiver that has occurred during the past fiscal year in their Exchange Act annual report. The SEC indicated that non-U.S. public companies may choose to disclose any change or waiver from the code of ethics obligations of its senior officers on a Form 6-K or its website. By when must a Company comply with the Code of Ethics Disclosure Requirements? Companies must comply with the code of ethics disclosure requirements promulgated under Section 406 of the Act in their annual reports for fiscal years ending on or after July 15, 2003. In addition, companies must comp

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