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 proactive audit plan that sought to a'>SCStShe effectiveness of the design of the company's antitrust policies and procedures. The plan also sought to deter mine whether antitrust compliance training was rolled out to relevant employees and whether such employees attended such training. The results of the 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