High-level personnel of the organization means individuals who have substantial control over the organization or who have a substantial role in the making of policy within the organization. The term includes: a director; an executive officer; an individual in charge of a major business or functional unit of the organization, such as sales, administration, or finance; and an individual with a substantial ownership interest. “High-level personnel of a unit of the organization” is defined in the Commentary to §8C2.5 (Culpability Score).
High-level personnel of the organization means individuals “who have substantial control over the organization or who have a substantial role in the making of policy within the organization[,]” such as directors, executive officers, individuals in charge of sales, administration, or finance, and individuals with substantial ownership interests.42 “Substantial authority personnel” means “individuals who within the scope of their authority exercise a substantial measure of discretion in acting on behalf of an organization[,]” such as plant managers, sales managers, individuals with authority to negotiate or set price levels, or individuals authorized to negotiate or approve significant contracts.43