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Division of Employee Accountability

A key to the success of a decentralized compliance program is the identification of employees with compliance oversight and ownership.

At each of the three Levels, identified employees will be evaluated and assessed on their commitment to achieving their compliance goals.

Level 1: Responsible Official

  • Foster an atmosphere of ethics, integrity, and compliance
  • Demonstrate commitment and visible willingness to let values drive decisions and articulate expectation that others should do the same
  • Exercise effective compliance and integrity oversight and monitoring
  • Integrate compliance and integrity expectations into performance evaluation criteria for direct reports with compliance obligations
  • Ensure each Supervisor establishes, communicates, and evaluates compliance expectations for each Point-of-Contact employee

Level 2: Compliance Supervisors

  • Ensure a corresponding Point-of-Contact employee is identified for each compliance area
  • Establish and communicate compliance and integrity expectations to each Point-of-Contact and other direct reports
  • Utilize metrics to assess Point-of-Contact employees’ efforts in achieving compliance and integrity objectives
  • Identify opportunities for creating a culture of constant improvement
  • Create an environment where employees feel comfortable reporting misconduct
  • Emphasize that a commitment to compliance is more important than a commitment to results; the means are as equally important as the ends

Level 3: Unit Point-of-Contact (POC)

  • The Point-of-Contact employee is the subject-matter-expert for their specific compliance area
  • Develop and communicate PRRs, SOPs, and best practices for compliance and integrity attainment
  • Develop subject matter information, resources and training content
  • Coordinate with compliance partners to move the entire network towards the attainment of compliance and integrity objectives
  • Strive for the attainment of the compliance and integrity objectives
  • Act ethically in all endeavors and report known or suspected incidents of misconduct