Question 1:  We are looking to understand what requirements drive the responsibility for subsidiary boards to approve policies (either their own policies or policies of the parent company)?

Question 2: Can you describe the process for subsidiary board approval of parent company policies:

·         Is this done annually for each subsidiary?

·         Does the Board see all of the policies or a policy summary? How are changes reported (new, revised, deleted policies)?

·         What kind of policy exceptions exist and how you track exceptions, if there are any. For example, how would a parent company policy that does not apply in the jurisdiction of the subsidiary be handled?

Company type: wholly owned subsidiary of a publicly traded company

Company size: large