


GENERAL SUMMARY The Vice President of Corporate Compliance oversees the Corporate Compliance Program, functioning as an independent and objective body that reviews and evaluates compliance issues/concerns within the organization. The position ensures the President that management and its employees are in compliance with the rules and regulations of regulatory agencies, that company policies and procedures are being followed, and that behavior in the organization meets the company’s Standards of Conduct. The Corporate Compliance Office exists: GENERAL PURPOSE The Vice President of Corporate Compliance reports to the President and provides monitoring and reporting results of the compliance/ethics efforts of the company and provides guidance to the senior management team on matters relating to compliance. The Vice President of Corporate Compliance, together with senior executive management, is authorized to implement all necessary actions to ensure achievement of the objectives of an effective compliance program. DUTIES AND RESPONSIBILITIES · Develops, initiates, maintains, and revises policies and procedures for the general operation of the Compliance Program and its related activities to prevent illegal, unethical, or improper conduct. Develops and periodically reviews and updates Standards of Conduct to ensure continuing currency and relevance in providing guidance to management and employees. Collaborates with other departments to direct compliance issues to appropriate existing channels for investigation and resolution. · Consults with the corporate attorney, as needed, to resolve difficult legal compliance issues. · Responds to alleged violations of rules, regulations, policies, procedures, and Standards of Conduct by evaluating or recommending the initiation of investigative procedures. · Develops and oversees a system for recording and uniform handling of such violations. · Acts as an independent review and evaluation body to ensure that compliance issues/concerns within the organization are being appropriately evaluated, investigated and resolved. Monitors, and as necessary, coordinates compliance activities including internal audits of other departments to remain current on the status of all compliance activities and to identify trends. · Identifies potential areas of compliance vulnerability and risk; develops/implements corrective action plans for resolution of problematic issues, and provides general guidance on how to avoid or deal with similar situations in the future. · Provides reports on a regular basis, and as directed or requested, to keep the President and senior management informed of the operation and progress of compliance efforts. · Ensures proper reporting of violations or potential violations to duly authorized enforcement agencies as appropriate and/or required. · Institutes and maintains an effective compliance communication program for the organization, including promoting (a) use of the Compliance Hotline; (b) heightened awareness of Standards of Conduct, and (c) understanding of new and existing compliance issues and related policies and procedures. · Works with the Human Resources Department and others as appropriate to develop an effective compliance training program, including appropriate introductory training for new employees as well as ongoing training for all employees and managers. · Tracking regulatory changes, industry rules, best practices, and guidance from the legal and accounting communities to ensure a "best of breed" compliance program; · Managing relationships with U.S. Government audit agencies, and other parties that may track or impact compliance practices. · Working with external consultants or counsel on matters concerning governance. · May oversee the Internal Audit, and Security Departments of the organization. · Ensuring vendors, contractors, agents and third parties are aware of compliance program with respect to billing practices, ethical behavior, etc. QUALIFICATIONS