Develops, initiates, maintains, and revises policies and procedures
for the general operation of the Compliance Program and its related
activities to prevent illegal, unethical, or improper conduct. Manages
day-to-day operation of the Program.
Develops and periodically reviews and updates Standards of Conduct
to ensure continuing currency and relevance in providing guidance to
management and employees.
Collaborates with other departments (e.g., Risk Management, Internal
Audit, Employee Services, etc.) to direct compliance issues to appropriate
existing channels for investigation and resolution. Consults with the
Corporate attorney as needed to resolve difficult legal compliance issues.
Responds to alleged violations of rules, regulations, policies, procedures, and
Standards of Conduct by evaluating or recommending the initiation of
investigative procedures. Develops and oversees a system for uniform
handling of such violations.
Acts as an independent review and evaluation body to ensure that compliance
Issues/concerns within the organization are being appropriately evaluated, investigated
and resolved.
Monitors, and as necessary, coordinates compliance activities of other
departments to remain abreast of the status of all compliance activities
and to identify trends.
Identifies potential areas of compliance vulnerability and risk; develops/implements
corrective action plans for resolution of problematic issues, and provides
general guidance on how to avoid or deal with similar situations in
the future.
Provides reports on a regular basis, and as directed or requested,
to keep the Corporate Compliance Committee of the Board and senior management
informed of the operation and progress of compliance efforts.
Ensures proper reporting of violations or potential violations to duly
authorized enforcement agencies as appropriate and/or required.
Establishes and provides direction and management of the compliance
Hotline.
Institutes and maintains an effective compliance communication program
for the organization, including promoting (a) use of the Compliance
Hotline; (b) heightened awareness of Standards of Conduct, and (c) understanding
of new and existing compliance issues and related policies and procedures.
Works with the Human Resources Department and others as appropriate
to develop an effective compliance training program, including appropriate
introductory training for new employees as well as ongoing training
for all employees and managers.
Monitors the performance of the Compliance Program and relates activities
on a continuing basis, taking appropriate steps to improve its effectiveness.
