Unwilling and unable to let such pemicious
allegations linger without a response,
tlie CCO woriced with the company's internal
audit function to develop a pR>active audit
plan that sought to assess the eftectiveness of
the design of tte company's antitmst policies
and procedures. The plan also .sought to determine
whether antitru.st compliance training
was rolled out to relevant employees and
whether such employees attended such training.
The results of tiie audit revealed that
antitmst training was rolled out in only a
handful of field locations, that employees RXItinely
disregiuxled training deadlines, and that
a significant numter of employees never
attended the training at all