Roles of the Compliance officer and the CCC
It shall be the responsibility of each department within the Company, but not the Compliance Officer or the CCC, to : i) establish the policies, standards or controls with respect to that department’s areas of potential compliance risk; and ii) conduct the requisite training and communication for such policies, standards or controls, either initially or as an update to ensure compliance. In instances of non-compliance, it shall be the responsibility of the Compliance Officer and the CCC to ensure that the instances of non-compliance has been properly reported within the Company and that corrective action is taken by the appropriate persons with respect to such non-compliance. The Compliance Officer is responsibility for preparing information about the Compliance Program that either the Company’s President or its Audit Committee requests or needs to meet their oversight responsibilities.