1. Policies, Procedures & Standards of Conduct
It communicates an organization's values and mission and the standards it sets for itself.
What is Code of Conduct?
This case established the standard for the Board of Directors duty of care.
What is Caremark? (BOD should make good faith effort to create systems that provide board members with information they need to manage a corporation in a way consistent with their duties of loyalty and care)?
OIG recommends these two kinds of education and training.
What is general and specific education?
They are basically two types of reviews where one is more rigorous, formal and independent, and the other is done on a daily or routine basis and does not require independence.
What is auditing and monitoring?
Discipline should always be ______, ________, and _____________.
What is fair, equitable, and consistent?
These documents are integral to the day-to-day operation of the organization
What is Policies and procedures?
They have a duty of oversight of the corporate compliance program.
What is the Chief Compliance Officer, Compliance Committees and the Board of Directors?
___________ are the most important lines of defense for a compliance program?
What is Education and training?
How often should an effective compliance program evaluate its processes?
What is constantly?
Disciplinary guidelines should be published in the ________________
What is standards of conduct?
It is better to ____________ than to have a policy that is not followed.
What is "not have a policy"?
How often should the Board review reports on the status of the compliance program?
What is at least annually?
At least ________ many hours of education and training are recommended for annual compliance training
What is at least 1 hour?
_________________ is a real time audit while _______________ looks at the past.
What is concurrent and retrospective audits?
Discipline should be _______________ to the offense.
What is proportionate?
Policies and procedures should be written at this reading level.
What is 8th grade?
Approves scope of compliance plan
What is the Board of Directors?
Employees should be required to _____________ upon completion of education and training.
What is attest?
Actual misconduct and _____________________ should result in disciplinary action.
What is "failure to detect or report misconduct"?
The three Cs of communication are _________
What is clear, concise and creative?
All employees must receive, read and understand the Code of Conduct within ____ days of hire.
What is ninety (90) days?
OIG and FSG require the designation of a _____________ to be the focal point of a compliance program.
What is compliance officer?
This kind of education and training is critical for high-risk areas or specialized personnel.
What is specific/focused training?
A _________________ policy is necessary for any reporting method.
What is a non-retaliation policy. What is a confidentiality policy?
This policy encourages effective communication
What is open-door policy (where the employees feel comfortable approaching supervisors and/or the compliance professional and openly discussing any potential problem; an open line of communication between Compliance and personnel)?