Description of Elements of Effective Compliance chart

1. Leadership and Oversight. Effective leadership and functional committee structures are in place, with regular reporting to the Board of Trustees.

2. Policies and Procedures. Clear expectations and practical guidance regarding behavior and decision-making are available and accessible.

3. Education and Outreach. Reasonable steps are taken to provide appropriate, relevant, and comprehensive education and outreach about compliance requirements.

4. Monitoring and Auditing. Program adherence to compliance requirements is monitored. Emerging and changing laws are tracked.

5. Receiving Reports and Investigating. Clear avenues exist to seek guidance or report violations of policy and relevant laws/regulations. Investigations follow appropriate processes and emphasize non-retaliation.

6. Accountability, Incentives and Corrective Action. Community members are encouraged to behave ethically and responsibly. Appropriate, fair and consistent actions are taken in cases of wrongdoing.

7. Response and Prevention. Episodes of misconduct and violations of laws, regulations and policies are responded to appropriately. Systemic issues are identified, root causes determined, and solutions implemented to prevent recurrence.