[M]anagers of legacy Lafarge operations were alleged to have had dealings with certain armed groups and sanctioned parties at Lafarge’s plant in Syria...[LafargeHolcim's Board] commissioned an internal investigation...[and] concluded that [the CEO] was not responsible...[as well as that] LCS [Lafarge Cement Syria] used intermediaries...without regard to the identity of the groups involved...The combination of the war zone chaos and the “can-do” approach...may have caused [local management] to seriously misjudge the situation...inconsistent with Lafarge’s policies. Its compliance program...failed to prevent these breaches...There have been significant changes and developments made to the compliance program and infrastructure since...