1. 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.
2. Develops and periodically reviews and updates Standards of Conducts to ensure continuing currency and relevance in providing guidance to management and employees.
3. Collaborates with other departments to direct compliance issues to appropriate existing channels for investigation and resolution.
4. Response to alleged violations of rules, regulations, policies, procedures, and Standard of Conduct by evaluating or recommending the initiation of investigation procedures. Develops and oversees a system for uniform handling of such violations.
5. Acts as an independent review and evaluation body to ensure that compliance Issues/concerns within the organization are being appropriately evaluated, investigated and resolved.
6. Monitors, and as necessary, coordinates compliance activities of other departments to remain abreast of the status of all compliance activities and to identify trends.
7. 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 situation in the future.
8. Provides reports on a regular basis, and as directed or requested, to keep the Corporate Compliance and senior management informed of the operation and progress of compliance efforts.
9. Ensure proper reporting of violations or potential violations to duly authorized enforcement agencies as appropriate and/or required.
10. Establishes and provides direction and management of the compliance Hotline.
11. Institutes and maintains an effective compliance communication program for the organization, including promoting (a) use of the Compliance Hotline, (b) heightened awareness of Standard of Conducts, (c) understanding of new and existing compliance issues and related policies and procedures.
12. Work 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.
13. Monitors the performance of the Compliance Program and relates activities on a continuing basis, taking appropriate steps to improve its effectiveness.