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responsibilities for specific compliance issues, such as employees responsible for billing <br /> government programs. In addition, the NSMT Compliance Officer may direct certain employees <br /> to attend additional continuing education classes. <br /> IV. TRAINING CONTENT - COMPLIANCE WITH NSMT's COMPLIANCE PROGRAM <br /> A. Employees shall be informed during the training session that compliance with the Compliance <br /> Program and the Code of Conduct is a condition of employment and that compliance with the <br /> Compliance Program and the Code of Conduct is one of the criteria upon which employees will be <br /> evaluated. <br /> B. Employees also may be required to participate in other mandatory training sessions. NSMT <br /> training sessions include, but are not limited to: sexual harassment, BBP, safety, and company <br /> policies. These sessions are in addition to those conducted by Compliance Officer pursuant to the <br /> Compliance Program. <br /> C. Failure to complete a training session conducted pursuant to the Compliance Program shall <br /> result in disciplinary procedures, up to and including discharge or teiinination from employment. <br /> D. Annually, each employee shall complete a Statement of Understanding which, among other <br /> items, certifies that he or she received and completed the general one-hour training session and any <br /> other training sessions applicable to that employee's position. The Compliance Officer shall keep <br /> these certifications on file for at least ten(10) years. The Statement can be completed <br /> electronically or hard copy. <br /> E. Managers and supervisors are responsible for ensuring adherence to the Compliance Program <br /> by the employees under their supervision. In this regard, it is the responsibility of every manager <br /> and/or supervisor to distribute all compliance guidance and revised training materials to every <br /> employee promptly upon receipt of the material. They must also infoini their subordinates regarding <br /> the requirements of, and compliance with, the Compliance Program. Supervisor and Managers are <br /> expected to maintain an open line of communication with their employees in which concerns can be <br /> reported and addressed without fear of retaliation. <br /> F. Managers and supervisors who fail to meet these requirements or fail to detect non-compliance <br /> with applicable policies and legal requirements,where reasonable diligence on the part of the manager <br /> or supervisor would have led to the discovery of any problems or violations and given NSMT an <br /> opportunity to correct them earlier, will be subject to disciplinary procedures,up to and including <br /> discharge or termination from employment. <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 /> 13 <br />