1.14 – Corporate Compliance

PostedFebruary 22, 2021

UpdatedMay 20, 2022

ByOpen Door

Summary/Objective

Open Door’s Corporate Compliance Officer is the Executive Director. In the absence of the Director, the Associate Director may act as the Compliance Officer. This role is responsible for establishment and implementation of an effective compliance program to prevent illegal, unethical or improper conduct.

All employees are required to report any illegal, unethical, or improper conduct immediately if it is observed or suspected. Any Open Door employee shall not be retaliated against or receive any negative employment measure based on their report of potential compliance issues.

If the complaint or report involves the Corporate Compliance Officer, the President of the Board of Directors must be notified and the investigation must be completed by the Board of Directors or designee.

The compliance officer monitors and reports results of the compliance and ethics efforts of the company. This roles also includes providing guidance for the Board and senior management team on matters relating to reporting and compliance. The corporate compliance officer, together with the Executive Committee, is authorized to implement all necessary actions to ensure achievement of the objectives of an effective compliance program, including the responsibility of the following:

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.

Manages day-to-day operation of the compliance program.

Develops and periodically reviews and updates Standards of Conduct to ensure continuing currency and relevance in providing guidance to management and employees.

Collaborates with other departments to direct compliance issues to appropriate existing channels for investigation and resolution.

Consults with general counsel as needed to resolve difficult legal compliance issues.

Responds to alleged violations of rules, regulations, policies, procedures and standards of conduct by evaluating or recommending the initiation of investigative procedures.

Develops and oversees a system for uniform handling of such violations.

Monitors, and as necessary, coordinates compliance activities of other departments to remain abreast of the status of all compliance activities and to identify trends.

Identifies potential areas of compliance vulnerability and risk, develops and implements corrective action plans for resolution of problematic issues, and provides general guidance on how to avoid or deal with similar situations in the future.

Provides reports on a regular basis and, as directed or requested, keeps the Board of Directors, the Corporate Executive Committee and senior management informed of the operation and progress of compliance efforts.

Ensures proper reporting of violations or potential violations to duly authorized enforcement agencies as appropriate or required.

Ensures that no employee is in any way retaliated against or receives any negative employment measures based on reporting potential compliance issues.

Establishes and provides direction and management of the compliance reports.

Institutes and maintains an effective compliance communication program for the organization, including promoting and training all employees on use of a specified contact number/information, heightened awareness of standards of conduct, and understanding of new and existing compliance issues and related policies and procedures.

Works with the human resource department and others as appropriate to develop an effective compliance training program, including appropriate introductory training for new employees and ongoing training for all employees and managers.

Monitors the performance of the compliance program and related activities on a continuing basis, taking appropriate steps to improve its effectiveness.