Ethics and Compliance Policies and Procedures (E&C Policies) are developed to address certain areas of legal or regulatory compliance risk. There are some aspects of the Company's Code of Conduct that are also expanded upon in E&C Policies.
The E&C Policies are provided to facility Ethics and Compliance Officers for notice and distribution within each facility; are posted on the Company's intranet; and are posted on the Company's external website. Individuals within a facility who have responsibility for a particular area of compliance risk addressed by policy are responsible for implementing relevant policies, conducting necessary monitoring and overseeing corrective action or process improvements.
Each E&C Policy is identified using a combination of letters and numbers. The first set of letters represent the originating department, e.g., EC for Ethics and Compliance. Some departments have generated policies which affect not only a function, but a particular area within a function. An example would be Billing policies that relate specifically to laboratory services. In many cases, the identifier will include a second set of letters to identify the specific area, e.g., LAB for laboratory services. The last section of the policy and procedure identifier will be a number denoting the sequence in which the policy and procedure was developed. For example, the first policy developed by Regulatory Compliance Support in the area of laboratory services would have the identifier REGS.LAB.001.