Continuous Improvement

Measuring and tracking our companies' compliance performance is important to the success of the Compliance & Integrity Program. Together with our companies, we are continuously seeking better, more efficient and more accurate methods to measure our compliance and integrity efforts.

Our focus on continuous improvement is outlined in the Altria Group Standards for Compliance and Integrity. Standard 9 requires that all Compliance and Integrity Plans include regular monitoring, auditing and evaluation. The priorities listed in the risk assessments and plans must also lead to specific action steps. Altria Group's Chief Compliance Officer annually reviews the compliance and integrity plans of Altria's companies, and reports their progress to the Audit Committee of Altria Group's Board of Directors.

Compliance Audits

To help keep our program on track, the Corporate Audit department supporting all of Altria Group's companies performs periodic reviews of certain compliance and integrity initiatives. This includes overall company program implementation, internal communications and training, management tracking of employee disclosures, allegations and investigations, as well as policy-specific compliance reviews at selected locations.

Employee Surveys

Periodically, we distribute compliance and integrity surveys to employees at Altria Group and its companies. These surveys focus on awareness, attitudinal and behavioral issues, and serve as a benchmark for future compliance and integrity initiatives. Employee feedback identifies key focus areas for continuous monitoring and improvement.

In addition to employee surveys, we also use focus groups and face-to-face feedback sessions to monitor the progress of our initiatives.

Additional Metrics

We maintain more formal measurement systems to capture quantitative measures of our efforts, including tracking the number of calls to our Integrity HelpLine; the nature of these calls; the rate of anonymity; the number of investigations and sanctions; and the number and types of compliance-related issues and questions raised through other departments. Altria's Chief Compliance Officer periodically provides reports on these metrics to the Audit Committee of the Altria Group's Board of Directors.

Related Information

Other Web Resources:

• Conference Board
• Compliance & Ethics Leadership Council
• Ethics & Compliance Officer Association
• Ethics Resource Center
• Society of Corporate Compliance & Ethics