REPORT ON ETHICS COMPLIANCE 04/02/15
|
|
- Logan Beasley
- 8 years ago
- Views:
Transcription
1 REPORT ON ETHICS COMPLIANCE 04/02/15
2 CONTENTS A. Online training on the Iberdrola Code of Ethics and IUSA Networks Annex to the Code of Ethics. 3 B. Reports made to the Compliance Unit for the purpose of (i) reporting suspected or actual compliance violations; and (ii) seeking guidance on ethics and compliance matters and policies. 3 C. Annual conflict of interest survey and compliance statement. 3 D. Actions taken by the IUSA Networks Board of Directors. 4 E. Crime Prevention Program. 4 F. Compliance reporting protocol. 4 G. Ethics and compliance communications to IUSA Networks employees. 4 H. background check screening of new employees, persons promoted to Director-level or higher, and third-party contractors. 4 I. Additional ethics and compliance training initiatives. 5 J. Ethics and compliance certifications by the Company s compliance officers. 5 K. Amendments to the Company s leadership model. 5 L. ETHIE and Ethisphere Awards. 5 2
3 This report describes actions taken by the Iberdrola USA Networks, Inc. ( IUSA Networks or the Company ) Compliance Unit and subsidiary management in connection with the Company s Compliance Program and 2014 Master Compliance Plan (the Compliance Plan ). The Compliance Plan was approved December 4, 2013, by the Audit and Compliance Committee of the Iberdrola USA Networks Board of Directors (the ACC ). This report is made annually pursuant to the ACC Charter adopted by IUSA Networks Board of Directors. Based on the overall results of the Compliance Plan and other compliance-related initiatives taken by IUSA Networks and its subsidiaries in 2014, including, without limitation, those reflected in this report, the IUSA Networks Chief Compliance Officer and the IUSA Networks Director of Compliance certified to the IUSA Networks ACC at its February 2015 meeting that the Compliance Program is effective and complies in all material respects with applicable legal and regulatory requirements. In addition, pursuant to a Crime Prevention Program adopted in 2014 and described below, the IUSA Networks Chief Compliance Officer certified to the IUSA Networks ACC that IUSA Networks had implemented internal controls, policies and procedures designed to ensure IUSA Networks material compliance with certain laws with criminal penalties applicable to the Company s activities. The following are some of the actions taken in 2014 that support the certification made by the Chief Compliance Officer and the Director of Compliance: A. Online training on the Iberdrola Code of Ethics and IUSA Networks Annex to the Code of Ethics. The Company s online Code of Ethics training was launched to approximately 4,150 Iberdrola USA Networks subsidiary employees and select thirdparty service providers in early October of The completion rate was 100%, excluding certain employees unable to take the. The following were notable changes to the 2014 training from prior versions: The substantive training materials were completely updated, based on a global training module developed by Iberdrola, S.A. A supplemental training module was developed to reflect U.S.-specific concepts, including those in the IUSA Networks Annex to the Code of Ethics. These included restrictions on affiliate transactions and state law gift and hospitality restrictions applicable to government employees. A new interactive format was used to stimulate trainee attention and learning. A quiz was added to the end of the training to confirm retention of key concepts. A statement regarding the reporting of potential violations and compliance with the Code of Ethics was included for confirmation by trainees. B. Reports made to the Compliance Unit for the purpose of (i) reporting suspected or actual compliance violations; and (ii) seeking guidance on ethics and compliance matters and policies. The following bullets summarize ethics and compliance complaints and reports made directly or indirectly to the Company s Compliance Unit during 2014, including those made through the Company s Ethics and Compliance Helpline (the Helpline ). In each case, the Compliance Unit received the support necessary from Company management to ensure an appropriate investigation of the reported matter. Helpline reports were received with respect to 32 matters during In twenty-two of these matters (66%), the reporter or reporters were anonymous. Nine of these matters were found not to be compliance or ethics-related, but instead to be business management issues. In these cases, reports were referred to the appropriate Business Area for resolution. There were also cases where multiple Helpline reports were received with respect to the same underlying circumstances. Accounting for these variables, the number of Helpline reports represents a slight decrease in volume from prior years but remains reasonable given the Company s total employee population. The top five most common subject areas for Helpline allegations were (1) human resources matters; (2) company policies; (3) workplace violence; (4) accuracy of company records (fraud); and (5) harassment and discrimination. These subject areas have consistently been the top five over previous years. There were eighty-four reports made directly to the IUSA Networks Director of Compliance, of which fifty-two (62%) were inquiries seeking ethics and policy guidance. There was a substantial increase in the number of inquiries seeking guidance compared to prior years, which is an indicator of further progress in the Program s maturity as employees seek guidance prior to taking questionable actions. These increases may also be attributable to improvements in Program communications and outreach. Included in the eighty-three reports were ethics and compliance matters implicating the Iberdrola Code of Ethics that were first reported to Human Resources or other departments and then referred to the Compliance Unit. C. Annual conflict of interest survey and compliance statement. The annual conflict of interest survey (the Survey ) was distributed to all IUSA Networks officers and salaried employees (1,708 individuals) in early November of The Survey completion rate was 100%, excluding individuals who were unable to complete the survey. The first four questions of the Survey were intended to facilitate disclosure of outside activities and potential conflicts of interests. A fifth question was intended to facilitate disclosure of potential violations of the Iberdrola Code of Ethics, the Annex, or a company policy, that had not previously been reported to the Compliance Unit, Human Resources, or other appropriate Company management. Each response to a question in the affirmative was reviewed by the IUSA Networks Director of Compliance to identify potential conflicts of interest and other compliance issues. The Survey also reminded respondents of their obligations under the Code of Ethics with respect to outside interests and potential conflicts of interest (e.g., disclosure and abstention). At the end of the Survey, respondents executed a statement confirming their obligation as IUSA Networks employees to comply with the Code of Ethics and other applicable Company policies and procedures. Based on the review of Survey responses, and follow-up inquiry where appropriate, no material conflicts of interest or violations of company policy were identified. 3
4 D. Actions taken by the IUSA Networks Board of Directors. The IUSA Networks Board of Directors and the ACC approved a number of new or amended policies, codes, and procedures in 2014 in support of the Compliance Program. Updated copies of certain of these documents are publicly-available on the Company s website. Actions taken by the Board of Directors are supported by operational policies and procedures established by Company management. The Board of Directors and ACC were trained on compliance-related subjects during the year, including, without limitation, the operations of the Compliance Program and the Board s corporate governance and oversight obligations with respect to ethics and compliance. In addition, Compliance Unit personnel met with the ACC several times in 2014 to provide updates on activities and to discuss the status of the Compliance Plan and other compliance-related matters. E. Crime Prevention Program. In 2014, the Compliance Unit, pursuant to direction from its Board of Directors, implemented a Crime Prevention Program intended to enhance and support IUSA Networks existing Compliance Program. This program is in furtherance of the Iberdrola Group s Crime Prevention and Anti-Fraud Policy, adopted by the Board of IUSA Networks, which requires the Company to implement an effective program for the prevention of criminal offenses. The Policy contemplates a system of controls aimed at preventing, detecting, and reacting to possible criminal offenses, as well as other forms of frauds, regulatory violations, and financial irregularities. In a company-wide collaboration including Legal Services, outside consultants, affected Business Areas, and the IUSA Networks Compliance Unit, certain criminal laws applicable to the Company s activities were mapped and Business Areas within the Company were designated as responsible for compliance. These Business Areas then underwent a process of identifying controls applicable to these laws. As with other elements of the Company s Compliance Program, the Crime Prevention Program will be the subject of continuous improvement and refinement efforts. F. Compliance reporting protocol. In 2014, the Compliance Unit for IUSA Networks and its subsidiaries developed protocols for managers to use for reporting known or suspected violations of laws, regulations, the Code of Ethics, and company policies. Such reports are required under the Code of Ethics. The goal of these protocols was to ensure that information regarding known or suspected violations is quickly communicated to the Compliance Unit or other appropriate departments for investigation and resolution. These protocols were disseminated to the Company s senior leadership and all levels of management using a combination of communication methods, including webinar trainings, and intranet notices, and in-person meetings. G. Ethics and compliance communications to IUSA Networks employees. In 2014, the Compliance Unit launched a formal communication plan intended to provide guidance and raise awareness among employees on common ethics and compliance issues. This communication plan included monthly articles disseminated by newsletter and . Examples of topics included: Vendor gifts and hospitality Conflicts of interest Workplace harassment Helpline reporting Political activity in the workplace Additional communications were disseminated throughout the year as opportunities arose to improve employee awareness of the Program. Subjects included, without limitation, publication of the Company s annual Ethics and Compliance and Separation of Activities reports, the anniversary of the Compliance Unit, and direct access to the Helpline from the Company s intranet homepage. H. Background check screening of new employees, persons promoted to Director-level or higher, and thirdparty contractors. Pursuant to Company policy, all prospective employees are subject to a criminal background check prior to being hired. Persons promoted or hired into a Director-level or higher position are subject to both criminal and civil background checks. Such persons are considered by IUSA Networks to be substantial authority personnel under the U.S. Federal Sentencing Guidelines. Human Resources is responsible for ensuring that background checks are initiated and processed in compliance with Company policies and applicable law. Human Resources confirmed to the Compliance Unit that required background checks were conducted on all new hires and all persons promoted to Director-level or higher between November 1, 2013 and October 31, 2014 (the annual review period). The Company has also implemented a Contractor Background Check Rule (the Rule ). The Rule generally requires that affected contractors periodically conduct criminal background checks on their employees who have regular access to the Company s sensitive assets, computer systems, and confidential information. The IUSA Networks Business Area that engages an outside contractor is responsible for enforcing the Rule. IUSA Networks Business Area Leaders certify compliance with the Rule on an annual basis (after appropriate due diligence). All affected IUSA Networks Business Area Leaders certified compliance with the Rule for the period of November 1, 2013 through October 31, 2014 (the annual certification period). 4
5 I. Additional ethics and compliance training initiatives. IUSA Networks and its operating subsidiaries conduct periodic trainings for compliance regarding certain regulations applicable to their industries, including anti-market manipulation rules, FERC standards for conduct, and affiliate transactions. In addition, new employee orientations included an overview of the Compliance Program, Helpline reporting, and the Company s commitment to ethical conduct and compliance with the law. Numerous other compliance-related trainings on particular subjects were conducted during the year for certain departments and employees. J. Ethics and compliance certifications by the Company s compliance officers. In 2014, the IUSA Networks Chief Compliance Officer and the IUSA Networks Director of Compliance, both licensed attorneys, earned distinction as Certified Compliance and Ethics Professionals by the Society of Corporate Compliance and Ethics. In addition, the IUSA Networks Director of Compliance earned certification as a Leading Professional in Ethics and Compliance by the Ethics and Compliance Officers Association. These certifications by leading organizations in the field of ethics and compliance recognize the expertise of the Company s compliance officers and contribute to the overall quality of the Company s Compliance Program. K. Amendments to the Company s leadership model. The Company recognizes that leadership and tone from the top are fundamental elements of an effective compliance program. In 2014, promotion of an ethical culture and leading with integrity were formally added to the Iberdola Leadership Model. This model is applied to Director-level and higher employees as the standard for evaluating effectiveness as a leader. Communications announcing this addition to the Iberdrola Leadership Model were disseminated to affected Company leadership. L. ETHIE and Ethisphere Awards. In 2014, the Rochester Business Ethics Foundation granted its annual ETHIE Award to the Company and its operating subsidiary, Rochester Gas and Electric Corporation. In its 12th year, the ETHIE is awarded by an independent panel of judges in recognition of a company s commitment to business ethics and good corporate citizenship. Also in 2014, the Company s global parent, Iberdrola, S.A., was recognized by the Ethisphere Institute was one of the world s most ethical companies. The Ethisphere Institute is an internationally recognized thought leader in the field of corporate ethics and compliance. This concludes the Iberdrola USA Networks Annual Report on Ethics and Compliance.
1. Online Training of Iberdrola Code of Ethics and IEH Annex to the Code of Ethics
Zarin Imam Iberdrola Energy Holdings, LLC Chief Compliance Officer Date: January 6, 2016 RE: 2015 Report on Ethics and Compliance This report describes actions taken by the Iberdrola Energy Holdings, LLC
More informationREPORT ON ETHICS COMPLIANCE 21/01/15
REPORT ON ETHICS COMPLIANCE 21/01/15 CONTENTS 1. Creation of Functional Program 3 2. Audit Committee and Board Interactions 3 Compliance-related training and corporate governance actions taken by the Iberdrola
More informationCorporate Compliance and Ethics Program Effective as adopted on February 21, 2012
Corporate Compliance and Ethics Program Effective as adopted on February 21, 2012 Page 1 of 7 SECTION 1. STATEMENT OF INTENT As a specialty pharmaceutical company and diagnostic laboratory, Prometheus
More informationCIVEO CORPORATION FINANCIAL CODE OF ETHICS FOR SENIOR OFFICERS. Effective as of May 5, 2014
CIVEO CORPORATION FINANCIAL CODE OF ETHICS FOR SENIOR OFFICERS Effective as of May 5, 2014 This Financial Code of Ethics for Senior Officers (this Financial Code ) of Civeo Corporation (the Company ) contains
More informationBoard of Directors Code of Conduct - 2010
CMS Energy Corporation Consumers Energy Company Board of Directors Code of Conduct - 2010 The CMS Energy Corporation ( CMS Energy ) and Consumers Energy Company ( Consumers ) Boards of Directors (the Board
More informationCOUPONS.COM INCORPORATED CHARTER OF THE AUDIT COMMITTEE OF THE BOARD OF DIRECTORS
COUPONS.COM INCORPORATED CHARTER OF THE AUDIT COMMITTEE OF THE BOARD OF DIRECTORS I. STATEMENT OF POLICY This Charter specifies the authority and scope of the responsibilities of the Audit Committee (the
More informationHALOZYME THERAPEUTICS, INC. CHARTER OF THE AUDIT COMMITTEE OF THE BOARD OF DIRECTORS ORGANIZATION AND MEMBERSHIP REQUIREMENTS
HALOZYME THERAPEUTICS, INC. CHARTER OF THE AUDIT COMMITTEE OF THE BOARD OF DIRECTORS I. STATEMENT OF POLICY The Audit Committee (the Committee ) of the Board of Directors (the Board ) of Halozyme Therapeutics,
More informationPHI Air Medical, L.L.C. Compliance Plan
Page No. 1 of 13 Introduction: The PHI Air Medical, L.L.C. is to be used by employees, contractors and vendors to get a high level understanding of the key regulatory requirements relating to our participation
More informationVCU HEALTH SYSTEM Compliance Program. Updated August 2015
VCU HEALTH SYSTEM Compliance Program Updated August 2015 Table of Contents Section I. Purpose of the Compliance Program... 3 Section II. Elements of an Effective Compliance Program... 3 A. Written Policies
More informationCompliance and Ethics Program
Compliance and Ethics Program Compliance and Ethics Program Introduction Inova, including its corporate subsidiaries, is committed to promoting an organizational culture that encourages ethical conduct
More informationCOUNTY OF ORANGE DEPARTMENT OF HEALTH. Corporate Compliance Plan
COUNTY OF ORANGE DEPARTMENT OF HEALTH Corporate Compliance Plan COUNTY OF ORANGE DEPARTMENT OF HEALTH CORPORATE COMPLIANCE PLAN I. Corporate Compliance Plan It is the policy of the Orange County Department
More informationCODE OF ETHICS FOR FINANCIAL PROFESSIONALS
CODE OF ETHICS FOR FINANCIAL PROFESSIONALS OWNER: Citi CFO CONTACT(S): CITI FINANCE ISSUE DATE: DECEMBER 24, 2004 REVISED DATE: APRIL 2014 Table of Contents 1 OVERVIEW 1 2 DIRECTIVE STATEMENT 2 3 DIRECTIVE
More informationSempra Energy Corporate Compliance and Ethics Plan This page is managed by the Director of Business Conduct (Last revised on 1 30 09)
Sempra Energy Corporate Compliance and Ethics Plan This page is managed by the Director of Business Conduct (Last revised on 1 30 09) Sempra Energy and its subsidiaries and affiliates ("Company") conduct
More informationBARRICK GOLD CORPORATION
BARRICK GOLD CORPORATION Code of Business Conduct and Ethics Introduction Barrick s success is built on a foundation of personal and professional integrity and commitment to excellence. As a company and
More informationDestiny Media Technology s Code of Conduct
Destiny Media Technology s Code of Conduct INTRODUCTION Destiny Media Technology s ( Destiny ) reputation depends on the conduct of its employees, officers and directors who have an obligation to Destiny
More informationPOLICY SUBJECT: EFFECTIVE DATE: 5/31/2013. To be reviewed at least annually by the Ethics & Compliance Committee COMPLIANCE PLAN OVERVIEW
Compliance Policy Number 1 POLICY SUBJECT: EFFECTIVE DATE: 5/31/2013 Compliance Plan To be reviewed at least annually by the Ethics & Compliance Committee COMPLIANCE PLAN OVERVIEW Sound Inpatient Physicians,
More informationCOMPLIANCE PROGRAM GUIDANCE FOR MEDICARE FEE-FOR-SERVICE CONTRACTORS
Department of Health and Human Services CENTERS FOR MEDICARE & MEDICAID SERVICES COMPLIANCE PROGRAM GUIDANCE FOR MEDICARE FEE-FOR-SERVICE CONTRACTORS March 2005 TABLE OF CONTENTS INTRODUCTION...3 ELEMENTS
More informationACNB CORPORATION & SUBSIDIARIES BOARD AUDIT COMMITTEE CHARTER
ACNB CORPORATION & SUBSIDIARIES BOARD AUDIT COMMITTEE CHARTER ORGANIZATION The Audit Committee is a committee of independent members of the Board of Directors. Its function is to assist the Board in fulfilling
More informationApproved by the Audit and Compliance Committee of the Providence Health & Services Board of Directors
Integrity and Compliance Description Approved by the Audit Committee of the Providence Health & Services Board of Directors December 7, 2009 Contents: Introduction Page 1 Purpose Page 2 Compliance Administration
More informationUMDNJ COMPLIANCE PLAN
UMDNJ COMPLIANCE PLAN INTRODUCTION...2 COMPLIANCE OVERSIGHT 3 COMPLIANCE COMMITTEE STRUCTURE...4 CHIEF COMPLIANCE OFFICER S RESPONSIBILITIES...5 RESEARCH COMPLIANCE.5 UNIT IMPLEMENTATION.6 COMPLIANCE POLICIES
More informationFERRARI N.V. AUDIT COMMITTEE CHARTER (Effective as of January 3, 2016)
FERRARI N.V. AUDIT COMMITTEE CHARTER (Effective as of January 3, 2016) For so long as shares of Ferrari N.V. (the Company ) are listed on the New York Stock Exchange ( NYSE ) and the rules of the NYSE
More informationELEMENT FINANCIAL CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS
APPENDIX I ELEMENT FINANCIAL CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS As of December 14, 2011 1. Introduction This Code of Business Conduct and Ethics ( Code ) has been adopted by our Board of Directors
More informationPOLICY AND PROCEDURES MANUAL FRAUD, WASTE, AND ABUSE
Page Number: 1 of 7 TITLE: PURPOSE: FRAUD, WASTE, AND ABUSE The Harris County Hospital District implemented a Corporate Compliance Program in an effort to establish effective internal controls that promote
More informationAntifraud program and controls assessment grid*
Advisory Services Antifraud program and * Fraud risks & controls February 2008 *connectedthinking 2008 PricewaterhouseCoopers LLP. All rights reserved. PricewaterhouseCoopers refers to PricewaterhouseCoopers
More informationCIVEO CORPORATION CORPORATE CODE OF BUSINESS CONDUCT AND ETHICS. Effective as of May 5, 2014
CIVEO CORPORATION CORPORATE CODE OF BUSINESS CONDUCT AND ETHICS Effective as of May 5, 2014 Purpose This Corporate Code of Business Conduct and Ethics (this Code ) contains the policies that relate to
More informationUNITED STATES COMMODITY FUNDS LLC CODE OF BUSINESS CONDUCT AND ETHICS
UNITED STATES COMMODITY FUNDS LLC CODE OF BUSINESS CONDUCT AND ETHICS TABLE OF CONTENTS Page Introduction... 1 Purpose of the Code... 1 Conflicts of Interest... 1 Corporate Opportunities... 2 Public Disclosure...
More informationCODE OF BUSINESS CONDUCT AND ETHICS
Effective: 1 st April 2015 Table of Contents 1. PURPOSE... 3 2. SCOPE... 3 3. OWNERSHIP... 3 4. DEFINITIONS... 3 5. CONFLICTS OF INTEREST... 3 6. CORPORATE OPPORTUNITIES... 4 7. CONFIDENTIALITY AND PRIVACY...
More information15 December 2015. Crime Prevention and Anti-Fraud Policy
15 December 2015 Crime Prevention and Anti-Fraud Policy Content 1. Purpose 3 2. Scope 3 3. Action Principles 3 4. Control, Evaluation, and Revision 4 Look after the Environment. Print in black and white,
More informationa. employees Company; or
Code of Busines ss Conduct and Ethics 1. Introduction a. This Code of Business Conduct and Ethics (the Code ) applies to all directors, officers, employees and third parties employed or directly engaged
More informationCHEVRON CORPORATION AUDIT COMMITTEE CHARTER
CHEVRON CORPORATION AUDIT COMMITTEE CHARTER PURPOSE The purpose of the Audit Committee (the Committee ) of the Board of Directors of Chevron Corporation (the Corporation ) is: 1. To assure that the Corporation
More informationMessage from the Co-Chairmen and Chief Executive Officers
Message from the Co-Chairmen and Chief Executive Officers As each of us works to meet individual and Company-wide business goals here at Torchmark, we must all ensure that the work we perform and the business
More informationUNIVERSITY COMPLIANCE PLAN
UNIVERSITY COMPLIANCE PLAN Objectives of the Compliance Program The University Compliance Program provides a proactive program that ensures full compliance with all applicable policies, procedures, laws
More informationUNIVERSAL INSURANCE HOLDINGS, INC. CODE OF BUSINESS CONDUCT AND ETHICS. Revised as of March 3, 2014
I. Statement of Policy UNIVERSAL INSURANCE HOLDINGS, INC. CODE OF BUSINESS CONDUCT AND ETHICS Revised as of March 3, 2014 Universal Insurance Holdings, Inc. ( UIH ) and its subsidiaries (collectively,
More informationFraud Policy FEBRUARY 2014
Fraud Policy FEBRUARY 2014 TABLE OF CONTENTS 1. Application of Policy... 2 2. Purpose of Policy... 2 3. Fraud Policy... 2 4. Definition of Fraud... 2 5. Duties and Responsibilities of an Employee or Contractor...
More informationGENERAL MILLS, INC. AUDIT COMMITTEE CHARTER
GENERAL MILLS, INC. AUDIT COMMITTEE CHARTER Organization. The Audit Committee (the Committee ) of General Mills, Inc. (the Company ) is a standing committee of the Board of Directors. The Committee shall
More informationIMAX CORPORATION PROTOCOL FOR REPORTING SUSPECTED VIOLATIONS OF THE IMAX CODE OF ETHICS. (Whistle Blower Program)
IMAX CORPORATION PROTOCOL FOR REPORTING SUSPECTED VIOLATIONS OF THE IMAX CODE OF ETHICS (Whistle Blower Program) November 2004 (updated February 2012) PROTOCOL FOR REPORTING SUSPECTED VIOLATIONS OF THE
More informationCORPORATE COMPLIANCE PROGRAM
CORPORATE COMPLIANCE PROGRAM BACKGROUND AND POLICY: The Oakwood Accountable Care Organization, LLC. ( ACO ) corporate policy relating to compliance with applicable laws and regulations is embodied in this
More informationCUBIC ENERGY, INC. Code of Business Conduct and Ethics
CUBIC ENERGY, INC. Code of Business Conduct and Ethics Introduction Our Company s reputation for honesty and integrity is the sum of the personal reputations of our directors, officers and employees. To
More informationBerkshire Hathaway Inc. Audit Committee Charter
Berkshire Hathaway Inc. Audit Committee Charter Committee Membership: The Audit Committee of Berkshire Hathaway Inc. (the Company ) shall be comprised of at least three directors, each of whom the Board
More informationSTRATEGIES FOR KEEPING A WHISTLEBLOWER IN-HOUSE. By Susan Goetz Markel
STRATEGIES FOR KEEPING A WHISTLEBLOWER IN-HOUSE By Susan Goetz Markel In 2012, the Securities and Exchange Commission issued its first whistleblower award under the new program ushered in by the Dodd-Frank
More informationReports of Compliance Concerns and Violations
The University of Chicago Medical Center Compliance Manual (UCHHS;BSD;UCPP) Reports of Compliance Concerns and Violations Issued: November 1, 1999 Reports of Compliance Concerns and Violations Revised:
More informationWIX.COM LTD. (THE COMPANY ) AUDIT COMMITTEE CHARTER
WIX.COM LTD. (THE COMPANY ) AUDIT COMMITTEE CHARTER The Board of Directors (the Board ) of the Company has constituted and established an Audit Committee (the Committee ) with the authority, responsibility
More informationThe ADT Corporation. Audit Committee Charter. December 2014
The ADT Corporation Audit Committee Charter December 2014 1 TABLE OF CONTENTS Purpose... 3 Authority... 3 Composition... 3 Meetings... 3 Responsibilities... 4 Financial Statements... 4 External Audit...
More informationYMCA of High Point Whistleblower Policy and Procedure
YMCA of High Point Whistleblower Policy and Procedure In keeping with the policy of maintaining the highest standards of conduct and ethics, the YMCA of High Point will investigate any suspected fraudulent
More informationRISK ASSESSMENT CHECKLIST
RISK ASSESSMENT CHECKLIST Provided By The Office of the Georgia State Inspector General Produced In Cooperation With The Governor s Office of Texas Fraud Risk Assessment Checklist Performing an agency
More informationINSTITUTIONAL COMPLIANCE PLAN
INSTITUTIONAL COMPLIANCE PLAN Responsible Party: Board of Trustees Contact: Institutional Compliance Office Original Effective Date: 02/16/2012 Last Revised Date: 10/13/2014 Contents I. SCOPE OF THE PLAN...
More informationCalifornia Mutual Insurance Company Code of Business Conduct and Ethics
California Mutual Insurance Company Code of Business Conduct and Ethics This Code of Business Conduct and Ethics (the Code ) applies to all officers, employees, and directors of California Mutual Insurance
More informationMental Health Resources, Inc. Mental Health Resources, Inc. Corporate Compliance Plan Corporate Compliance Plan
Mental Health Resources, Inc. Mental Health Resources, Inc. Corporate Compliance Plan Corporate Compliance Plan Adopted: January 2, 2007 Revised by Board of Directors on September 4, 2007 Revised and Amended
More informationAUDIT COMMITTEE BEST PRACTICES CHECKLIST
AUDIT COMMITTEE BEST PRACTICES CHECKLIST General 1. Members have the appropriate predefined qualifications to meet the objectives of the audit committee s charter, including appropriate financial literacy.
More informationCARE.COM, INC. CORPORATE GOVERNANCE GUIDELINES
CARE.COM, INC. CORPORATE GOVERNANCE GUIDELINES The Board of Directors (the Board ) of Care.com, Inc. (the Company ) has adopted the following Corporate Governance Guidelines (these Guidelines ) to assist
More informationUnderstanding Your Ethics & Code of Conduct Training Requirements. May 29, 2008
Understanding Your Ethics & Code of Conduct Training Requirements May 29, 2008 Shanti Atkins, Esq. President & CEO of ELT. Specialist in online ethics and legal compliance training. Advises clients across
More informationEstablishing An Effective Corporate Compliance Program Joan Feldman, Esq. Vincenzo Carannante, Esq. William Roberts, Esq.
Establishing An Effective Corporate Compliance Program Joan Feldman, Esq. Vincenzo Carannante, Esq. William Roberts, Esq. November 11, 2014 Shipman & Goodwin LLP 2014. All rights reserved. HARTFORD STAMFORD
More informationProviders are expected to conduct their business activities in full compliance with all applicable state and federal laws.
8. Compliance KP strives to demonstrate high ethical standards in its business practices. The Agreement details specific laws and contractual provisions with which you are expected to comply. This section
More informationINTUITIVE SURGICAL, INC. CORPORATE GOVERNANCE GUIDELINES
INTUITIVE SURGICAL, INC. CORPORATE GOVERNANCE GUIDELINES The Board of Directors (the Board ) of Intuitive Surgical, Inc., a Delaware corporation (the Company ), has adopted the following Corporate Governance
More informationMontgomery County, Unique Aspects of the Medicaid Control System
MONTGOMERY COUNTY POLICY AND PROCEDURE Date Drafted: 12/07/09 Date Approved: 12/15/09 Date(s) Revised: I. POLICY: It is the policy of Montgomery County to promote compliance with all federal, state, and
More informationThe University of Texas at Austin COMPLIANCE AND ETHICS PROGRAM CHARTER
The University of Texas at Austin COMPLIANCE AND ETHICS PROGRAM CHARTER Purpose The purpose of the University of Texas at Austin ( University ) Compliance and Ethics Program ( CEP ) is to promote and support
More informationCompliance Program and HIPAA Training For First Tier, Downstream and Related Entities
Compliance Program and HIPAA Training For First Tier, Downstream and Related Entities 09/2011 Training Goals In this training you will gain an understanding of: Our Compliance Program elements Pertinent
More informationAMPLIFY SNACK BRANDS, INC. AUDIT COMMITTEE CHARTER. Adopted June 25, 2015
AMPLIFY SNACK BRANDS, INC. AUDIT COMMITTEE CHARTER Adopted June 25, 2015 I. General Statement of Purpose The purposes of the Audit Committee of the Board of Directors (the Audit Committee ) of Amplify
More informationSummary. ViiV Healthcare Compliance Program U.S. Operations
ViiV Healthcare Compliance Program U.S. Operations Summary ViiV Healthcare Company (the Company or VH ) is committed to conducting its business with honesty and integrity, and with high standards for ethical
More informationEvergreen Solar, Inc. Code of Business Conduct and Ethics
Evergreen Solar, Inc. Code of Business Conduct and Ethics A MESSAGE FROM THE BOARD At Evergreen Solar, Inc. (the Company or Evergreen Solar ), we believe that conducting business ethically is critical
More informationAMTRUST FINANCIAL SERVICES, INC. AUDIT COMMITTEE CHARTER
Audit Committee Charter AMTRUST FINANCIAL SERVICES, INC. AUDIT COMMITTEE CHARTER Audit Committee Purpose The Audit Committee ( Committee ) is appointed by the Board of Directors of AmTrust Financial Services,
More informationSanchez Energy Corporation. Code of Business Conduct and Ethics
Sanchez Energy Corporation Code of Business Conduct and Ethics Introduction The Board of Directors (the Board ) of Sanchez Energy Corporation (the Company ) has adopted this Code of Business Conduct and
More informationcompany policy number 0001 LEGAL AND ETHICAL CONDUCT
company policy number 0001 LEGAL AND ETHICAL CONDUCT eff. date replaces page 28 Mar. 2011 14 Feb. 2006 1 of 10 PURPOSE CPI has adopted this Code of Legal and Ethical Conduct ( Code ) to promote: honest
More informationCompliance Requirements for Healthcare Carriers
INFORMATION DRIVES SOUND ANALYSIS, INSIGHT REGULATORY COMPLIANCE ADVISORY Compliance Requirements for Healthcare Carriers Introduction With the introduction of the new healthcare exchanges in January 2014
More informationWe will pursue our business with honor, fairness, and respect for the individual and. the public at large ever mindful that there
O Business with Integrity O We will pursue our business with honor, fairness, and respect for the individual and the public at large ever mindful that there is no right way to do a wrong thing. Introduction
More informationOffice of Compliance and Ethics Introductory Report. Lynette Fons, Chief Compliance Officer
Office of Compliance and Ethics Introductory Report Lynette Fons, Chief Compliance Officer Why the Office of Compliance and Ethics was Created The City operates in a highly complex regulatory environment
More informationPASSUR AEROSPACE, INC (the "Company") AUDIT COMMITTEE CHARTER. The purpose of the Audit Committee (the Committee ) shall be as follows:
Purpose PASSUR AEROSPACE, INC (the "Company") AUDIT COMMITTEE CHARTER The purpose of the Audit Committee (the Committee ) shall be as follows: 11. To oversee the accounting and financial reporting processes
More informationFERRELLGAS CODE OF ETHICS FOR PRINCIPAL EXECUTIVE AND FINANCIAL OFFICERS
FERRELLGAS CODE OF ETHICS FOR PRINCIPAL EXECUTIVE AND FINANCIAL OFFICERS I. PURPOSE OF THE CODE The Ferrellgas Code of Ethics (this Code ) is intended to serve as the code of ethics described in Section
More informationCHARTER FOR THE AUDIT COMMITTEE OF THE BOARD OF DIRECTORS SIGMA DESIGNS, INC. (As adopted by the Board of Directors effective as of May 2010)
CHARTER FOR THE AUDIT COMMITTEE OF THE BOARD OF DIRECTORS OF SIGMA DESIGNS, INC. (As adopted by the Board of Directors effective as of May 2010) PURPOSE: The purpose of the Audit Committee of the Board
More informationEADS-NA Code of Ethics
Page: 1 of 7 EADS-NA Code of Ethics Introduction The Company demands high ethical standards of conduct from its directors, employees, and agents and will conduct its business with honesty, integrity, and
More informationCharter of the Audit Committee of the Board of Directors of Woodward, Inc.
AUDIT COMMITTEE CHARTER Charter of the Audit Committee of the Board of Directors of Woodward, Inc. Purpose The Audit Committee (the Committee ) is appointed by the Board of Directors to oversee the accounting
More informationBoard of Directors and Management Oversight
Board of Directors and Management Oversight Examination Procedures Examiners should request/ review records, discuss issues and questions with senior management. With respect to board and senior management
More informationFIRST CITIZENS BANCSHARES, INC. FIRST-CITIZENS BANK & TRUST COMPANY CHARTER OF THE JOINT AUDIT COMMITTEE
FIRST CITIZENS BANCSHARES, INC. FIRST-CITIZENS BANK & TRUST COMPANY CHARTER OF THE JOINT AUDIT COMMITTEE As amended, restated, and approved by the Boards of Directors on July 28, 2015 This Charter sets
More informationSM ENERGY COMPANY CODE OF BUSINESS CONDUCT AND CONFLICT OF INTEREST POLICY
SM ENERGY COMPANY CODE OF BUSINESS CONDUCT AND CONFLICT OF INTEREST POLICY We at SM Energy Company are committed to compliance with applicable laws, rules and regulations and to conducting our business
More informationPAPA JOHN S INTERNATIONAL, INC. CODE OF ETHICS AND BUSINESS CONDUCT
PAPA JOHN S INTERNATIONAL, INC. CODE OF ETHICS AND BUSINESS CONDUCT Approved October 30, 2015 Dear Officers, Directors and Team Members: All of us, together with our investors, customers and supply partners,
More informationNorth Shore LIJ Health System, Inc.
North Shore LIJ Health System, Inc. POLICY TITLE: Detecting and Preventing Fraud, Waste, Abuse and Misconduct POLICY #: 800.09 System Approval Date: 6/23/14 Site Implementation Date: Prepared by: Office
More informationCHANGYOU.COM LIMITED AUDIT COMMITTEE CHARTER
CHANGYOU.COM LIMITED AUDIT COMMITTEE CHARTER I. Composition of the Audit Committee: There will be a committee of the Board of Directors to be known as the Audit Committee. The Audit Committee will have
More informationTime Warner Cable Inc. Audit Committee Charter. Effective February 14, 2013
Time Warner Cable Inc. Audit Committee Charter Effective February 14, 2013 The Board of Directors of Time Warner Cable Inc. (the Corporation ; Company refers to the Corporation and its consolidated subsidiaries)
More informationC&J ENERGY SERVICES LTD. CORPORATE CODE OF BUSINESS CONDUCT AND ETHICS (Adopted as of March 24, 2015)
CORPORATE CODE OF BUSINESS CONDUCT AND ETHICS (Adopted as of March 24, 2015) The Board of Directors (the Board ) of C&J Energy Services Ltd. (the Company ) has adopted this Corporate Code of Business Conduct
More informationHILLENBRAND, INC. AND SUBSIDIARIES. Global Anti-Corruption Policy Statement and Compliance Guide
HILLENBRAND, INC. AND SUBSIDIARIES Global Anti-Corruption Policy Statement and Compliance Guide Hillenbrand, Inc., including all of its subsidiaries (referred to collectively as the Company ), maintains
More informationVANDA PHARMACEUTICALS INC.
VANDA PHARMACEUTICALS INC. CODE OF ETHICS AND BUSINESS CONDUCT (As of May 22, 2014) 1. POLICY STATEMENT The reputation and integrity of Vanda Pharmaceuticals Inc. (the Company ) are valuable assets that
More informationCODE OF ETHICS AND BUSINESS CONDUCT
CODE OF ETHICS AND BUSINESS CONDUCT Date of Issue: 22 January 2015 Version number: 2 LUXFER HOLDINGS PLC Code of Ethics and Business Conduct Luxfer Holdings PLC is committed to conducting its business
More informationCFPB Consumer Laws and Regulations
General Principles and Introduction Supervised entities within the scope of CFPB s supervision and enforcement authority include both depository institutions and non-depository consumer financial services
More informationCOLUMBUS GOLD CORP. (the Company ) WHISTLEBLOWER POLICY
COLUMBUS GOLD CORP. (the Company ) WHISTLEBLOWER POLICY I. PURPOSE OF THIS POLICY A. The Code of Conduct (the Code ) of Columbus Gold Corp. (the Company ) requires every officer, director and employee
More informationCompany s Audit and a Review of the Outside Auditor
CLARCOR INC. AUDIT COMMITTEE OF THE BOARD OF DIRECTORS CHARTER PURPOSES: The purpose of the Committee is to: (a) assist Board oversight of (i) the integrity of the Company s financial statements, (ii)
More informationExponent, Inc. Charter of the Audit Committee of the Board of Directors (as amended through December 10, 2015)
Exponent, Inc. Charter of the Audit Committee of the Board of Directors (as amended through December 10, 2015) Charter of the Audit Committee of the Board of Directors I. Audit Committee Purpose The purpose
More informationIMMUNOTEC INC. AUDIT AND DISCLOSURE POLICY MANAGEMENT COMMITTEE CHARTER AND WHISTLEBLOWER POLICY
IMMUNOTEC INC. AUDIT AND DISCLOSURE POLICY MANAGEMENT COMMITTEE CHARTER AND WHISTLEBLOWER POLICY ORGANIZATION There shall be a committee of the Board of Directors of the Corporation (the Board ) to be
More informationEFFECT OF THE SARBANES-OXLEY ACT OF 2002
EFFECT OF THE SARBANES-OXLEY ACT OF 2002 August 15, 2002 President Bush signed the Sarbanes-Oxley Act of 2002 (the Act ) into law on July 30, 2002, after numerous business and accounting scandals had rocked
More informationAsterias Biotherapeutics, Inc. Code Of Business Conduct And Ethics. March 10, 2013
Asterias Biotherapeutics, Inc. Code Of Business Conduct And Ethics March 10, 2013 This Code of Business Conduct and Ethics (the "Code") sets forth legal and ethical standards of conduct for directors,
More informationAUDIT COMMITTEE OF THE TRUSTEES TEXAS PACIFIC LAND TRUST CHARTER
Amended and Restated: February 24, 2010 AUDIT COMMITTEE OF THE TRUSTEES OF TEXAS PACIFIC LAND TRUST CHARTER PURPOSE The primary function of the Committee is to assist the Trustees of the Trust in discharging
More informationCHARTER OF THE AUDIT COMMITTEE OF THE BOARD OF DIRECTORS
CHARTER OF THE AUDIT COMMITTEE OF THE BOARD OF DIRECTORS PURPOSE The Audit Committee (the Audit Committee ) is appointed by the Board of Directors (the Board ) of NVIDIA Corporation, a Delaware corporation
More informationMOREHOUSE COLLEGE. Standards of Conduct Guide
MOREHOUSE COLLEGE Standards of Conduct Guide Purpose Compliance Risk Management Program 1. Ethical Standards TABLE OF CONTENTS 2. Contacts with the media, government and outside investigators 3. Records
More informationMATTEL, INC. AMENDED AND RESTATED AUDIT COMMITTEE CHARTER
Purpose MATTEL, INC. AMENDED AND RESTATED AUDIT COMMITTEE CHARTER The purpose of the Audit Committee (the Committee ) is to provide assistance to the Board of Directors (the Board ) of Mattel, Inc. (the
More informationAudit Committee Charter Altria Group, Inc. In the furtherance of this purpose, the Committee shall have the following authority and responsibilities:
Audit Committee Charter Altria Group, Inc. Membership The Audit Committee (the Committee ) of the Board of Directors (the Board ) of Altria Group, Inc. (the Company ) shall consist of at least three directors
More informationVILLAGECARE CORPORATE COMPLIANCE POLICY AND PROCEDURE MANUAL ORIGINAL EFFECTIVE DATE: JANUARY 1, 2007
VILLAGECARE CORPORATE COMPLIANCE POLICY AND PROCEDURE MANUAL SUBJECT: COMPLIANCE WITH FEDERAL AND STATE FALSE CLAIMS LAWS AND DETECTION AND PREVENTION OF FRAUD, WASTE AND ABUSE LAST POLICY REVISION EFFECTIVE
More informationCSX CORPORATION. Board of Directors. Corporate Governance Guidelines
CSX CORPORATION Board of Directors Corporate Governance Guidelines The following guidelines have been adopted by the Board of Directors and, together with the charters of the standing Board committees,
More informationWHAT IS A COMPLIANCE PLAN
Code of Conduct WHAT IS A COMPLIANCE PLAN AND CODE OF CONDUCT? The Compliance Plan and Code of Conduct are formal statements of EPIC s standards and rules of ethical business conduct. We need a Compliance
More informationCHARTER OF THE AUDIT COMMITTEE OF THE BOARD OF DIRECTORS OF ARMSTRONG FLOORING, INC. ADOPTED AS OF MARCH 30, 2016
CHARTER OF THE AUDIT COMMITTEE OF THE BOARD OF DIRECTORS OF ARMSTRONG FLOORING, INC. ADOPTED AS OF MARCH 30, 2016 I. PURPOSE OF THE COMMITTEE The purpose of the Audit Committee (the Committee ) of the
More informationEVOGENE LTD. (THE COMPANY ) AUDIT COMMITTEE CHARTER
EVOGENE LTD. (THE COMPANY ) AUDIT COMMITTEE CHARTER The Board of Directors (the Board ) of the Company has constituted and established an Audit Committee (the Committee ) with the authority, responsibility
More informationWhite Paper: The Seven Elements of an Effective Compliance and Ethics Program
White Paper: The Seven Elements of an Effective Compliance and Ethics Program Executive Summary Recently, the United States Sentencing Commission voted to modify the Federal Sentencing Guidelines, including
More information