Unwilling and unable to let such pernicious allegations linger without a response, the CCO worked with the company's internal audit function to develop a pR>active audit plan that sought to assess the effectiveness of the design of the company's antitrust policies and procedures. The plan also sought to determinewhether antitrust compliance training was rolled out to relevant employees and whether such employees attended such training. The results of tiie audit revealed that antitrust training was rolled out in only a handful of field locations, that employees routinely disregarded training deadlines, and that a significant number of employees never attended the training at all