Corporate Compliance

Basic Elements

1. Standards and Procedures:
Establish compliance standards through the development of a code of conduct and written policies and procedures;

1. Code of Conduct
2. Written Policies and Procedures
3. Outline Legal Duty
4. Attestation

2. Oversight:
Establish proper oversight of the Compliance Program and compliance efforts.

1. Corporate Compliance Officer
2. CEO
3. Audit Committee of the Board of Directors
4. Board of Directors

3. Education and Training:
Conduct effective training and education on compliance related procedures in an effort to ensure that employees are knowledgeable of, and comply with pertinent federal and state standards;

4. Monitoring and Auditing:
Establish an ongoing program for monitoring compliance risk areas;

5. Reporting and Investigation:
Investigate any report or allegation concerning possible unethical or improper business practices and monitoring subsequent corrective action and/or compliance. Establish an open line of communication (Hotline) for employees to submit reports, complaints or questions regarding compliance. Employees and others must be assured that reports can be made anonymously and without fear of retribution.

6. Enforcement and Discipline:
Enforcing disciplinary standards by making clear or ensuring that compliance is treated seriously and that violations will be dealt with consistently and uniformly;

1. Sanctions for non-compliant behavior
2. Consistency

7. Response and Prevention:
Establish a process to assess and investigate all reported compliance issues. The process will include steps to revise and/or create policy to mitigate reoccurrence.