Upon hire and periodically thereafter, all employees are required to review an organization's Code of Conduct and applicable Compliance Policies. Each employee must certify that he has received the documents, read and understood their contents, and agree to abide by the letter and spirit of each.
Managers and supervisors are responsible for ensuring that their direct subordinates receive and understand the Code of Conduct, the applicable Compliance Policies and any supplemental Standard Policies to which they are subject.
The purpose of these Policies is to ensure that the mandatory employee training requirements under the Compliance Program are implemented. Every employee must understand the ethical and legal standards to which they must adhere.
The Compliance Program is introduced by the distribution of the Code of Conduct and mandatory attendance to compliance training sessions.
Your Compliance Committee may periodically instruct one or more of your practice's employees to undertake the Auditing and Monitoring of your Compliance Program. All employees are expected to assist and fully cooperate with this effort. From time to time, an organization may also choose to have auditors and investigators from outside our organization involved in the process of reviewing and auditing the effectiveness of your Compliance Program. These auditors and investigators may differ from the persons conducting internal investigations – in addition to investigating specific reports of violations, they may be conducting broad reviews of how the Compliance Program is operating or specific legal or regulatory compliance. Even though these auditors and investigators may not be investigating a specific violation, it is still absolutely necessary that employees cooperate with their investigations as fully as they would if a violation of the law were at issue.