Unwilling and unable to let such pernicious
allegations linger without a response,
tlie 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 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 routinely
disregarded training deadlines, and that
a significant numter of employees never
attended the training at all