10-09-17 Regular Meeting of the La Porte City Council

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1.1 ŷğƷ ğƩĻ ƷŷĻ ƩĻƨǒźƩĻķ ĭƚƒƦƚƓĻƓƷƭ ƚŅ ğƓ LƓƷĻƩƓğƌ /ƚƒƦƌźğƓĭĻ tƩƚŭƩğƒʹ Internal Compliance Program must be in ǞƩźƷźƓŭ and must provide compliance standards and procedures that the employees and agents are expected to follow. 1) High level personnel are responsible for oversight of compliance with the standards and procedures A written policy designating the individual(s) by title that shall be responsible for oversight of the internal ethics and compliance program. The person shall promote an organizational culture that encourages ethical conduct and a commitment to compliance with all applicable laws and regulations. (2) Appropriate care is being taken to avoid the delegation of substantial discretionary authority to individuals whom the entity knows, or should know, have a propensity to engage in illegal activities A written policy that details the background vetting process (background checks, federal/state debarment, application disclosures, affirmation statement, of current and future employees/board members that will have substantial discretionary authority and are involved in the handling of financial and/or highly confidential information. (3) Ensure that compliance standards and procedures are effectively communicated to all of the entity's employees, including members of the governing board if the entity has a governing board, by requiring them to participate in periodic training in ethics and in the requirements of the program. A written policy that requires employees and members of the governing board to participate in periodic (monthly, quarterly, annually, training in (1) ethics and (2) in the components of its Internal Compliance Program. (4) Ensure that compliance standards and procedures are effectively communicated to all of the entity's agents A written policy that requires notification to agents (persons or entities authorized to act on behalf of the organization) of their obligation to adhere to the Internal Compliance Program (5a) Reasonable steps are being taken to achieve compliance with the compliance standards and procedures by using monitoring and auditing systems that are designed to reasonably detect noncompliance. A written policy detailing established processes (Internal Audit/Compliance Charter, Annual Risk Assessment, Annual Audit/Compliance Work Plan, Enterprise Risk management, Governance, Risk, and Control Policy and Procedures, Fraud Risk Policy, Quarterly Monitoring Plan, for assessing compliance with its code of conduct as well as policies and procedures adopted to promote adherence with laws and regulations. An organization may not solely rely on an annual external audit for compliance with this requirement. (5b) Reasonable steps are being taken to achieve compliance with the compliance standards and procedures by providing and publicizing a system for the entity's employees and agents to report suspected noncompliance without fear of retaliation A written policy detailing a reporting system (Hotline, Website, Internal Communication Channels, etc.), which may include mechanisms for anonymity or confidentiality that allows employees, the governing board and entity agents to report suspected incidents of non-compliances without fear of retaliation. (6) Consistent enforcement of compliance standards and procedures is administered through appropriate disciplinary mechanisms A written policy outlining how the entity responds to incidents of non-compliance in conformance with its internal disciplinary process.