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Policy on Employee Training <br /> 1. INTRODUCTION <br /> NSMT recognizes that for this Compliance Program to be effective, employees must receive education <br /> and training as to the importance of compliance with applicable law and the Compliance Program. In <br /> this regard, NSMT has developed a training program for all of its employees so that all employees are <br /> familiar with the Compliance Program and understand all of its policies and procedures, including the <br /> Code of Conduct. <br /> IL IMPLEMENTATION <br /> A. As part of new hire orientation, all new employees will complete a one hour training session <br /> within the first thirty(30)days of employment that discusses the goals and objectives of the <br /> Compliance Program and familiarizes new employees generally with the Compliance Program. At <br /> the conclusion of the training session,new employees will be asked to complete the Statement of <br /> Understanding that they are aware of, understand, and will abide by the Compliance Program and <br /> Code of Conduct and Ethics. The Statement may be completed electronically if the training is <br /> completed online. <br /> B. After the initial orientation, all existing employees will receive annual training on the <br /> Compliance Program and Code of Conduct. In this training session, employees will review the <br /> existing Compliance Program, the Code of Conduct, any applicable policies and procedures, and <br /> will discuss material changes in these policies and procedures. The training session also will focus <br /> upon changes in federal laws and regulations. This training session will be conducted at the <br /> direction of the Compliance Officer. The training session may be completed online, or if needed <br /> face-to-face. When face-to-face training is necessary employees will sign an attendance form <br /> immediately after each face-to-face training session. The executed attendance form shall be filed in <br /> the secure Compliance department. Each employee must complete a minimum of at least one (1) <br /> hour of Compliance Program training every calendar year. Employees completing the training <br /> online will complete the Acknowledgment Form electronically. The Form will be tracked <br /> electronically by the Compliance department. An employee returning from leave, who has missed a <br /> regularly scheduled training session, must complete the training session within thirty(30)days of <br /> return. <br /> III. TRAINING SESSIONS <br /> A. The NSMT Compliance Department shall be responsible for developing and oversight of the <br /> annual training and new hire orientation sessions. The Compliance Officer shall keep a record of all <br /> such training sessions either electronically or via hard copy. Additional training sessions may be <br /> conducted as the need arises. When necessary, the Compliance Officer will take attendance at all <br /> training sessions with a Sign-In Form and will maintain a record of course attendance at any training <br /> session which is performed as part of the Compliance Program. Participation in and attendance at <br /> training sessions is mandatory and attendance of training sessions, including Code of Conduct, will <br /> be one of the criteria for which employees will be evaluated during their annual reviews. <br /> B. At the direction of the Compliance Officer, other training sessions may be held as the need <br /> arises to address changes in the NSMT Compliance Program, federal laws and regulations, or <br /> other issues of interest. Additional training sessions may be conducted for employees who have <br /> 12 <br />