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Policy on Compliance Committee <br /> PURPOSE: <br /> Although it is the responsibility of all personnel to comply with the NSMT Compliance Program, NSMT has <br /> adopted this Compliance Committee Policy in order to establish a committee of personnel to have primary <br /> responsibility of the NSMT Compliance Program. Day-to-day administrative responsibilities are assigned to <br /> the NSMT Compliance Officer(CO). <br /> POLICY AND PROCEDURE: <br /> The NSMT Compliance Committee's responsibilities include: <br /> • Ensuring the proper evaluation and response to ethical and regulatory issues and concerns. Reviewing and <br /> revising NSMT compliance policies to ensure the standards are reasonably capable of reducing improper <br /> conduct. <br /> • Recommending and monitoring educational and teaching activities to ensure the Company's standards and <br /> procedures are communicated effectively to all employees. <br /> • Assessing results of internal/external reviews to achieve compliance with the NSMT standards. <br /> • Analyzing reports of misconduct and recommending and monitoring appropriate corrective action. <br /> • Ensuring proper enforcement with the Company's standards and procedures through appropriate disciplinary <br /> measures. <br /> Developing and publicizing a confidential reporting system that enables personnel and to report improper <br /> conduct without fear of retaliation. <br /> • The Compliance Officer/Committee is responsible for developing meeting agendas and distributing pertinent <br /> review information to members. <br /> • Members will be reviewed and set annually. <br /> • Members of this Committee include,but are not limited to (SEE ATTACHED) <br /> POLICY REVIEW <br /> The NSMT Compliance Officer will review and update this Policy and all Compliance policies when <br /> necessary in the normal course of its review of the NSMT Compliance Program. <br /> 9 <br />