Hotline, Comment Box and Communication
A. Hotline
The Company maintains a Hotline telephone number to allow the communication of information regarding compliance issues to the Compliance Officer. The Hotline will also serve as a reporting option for Employees and Contractors with information about suspected misconduct.
Any Employee or Contractor who is aware of a breach (or potential breach) of this Plan or other unethical or improper employee conduct is encouraged to report such concern through the Hotline or directly to the Compliance Officer.
Employees and Contractors may use the Hotline to report matters on an anonymous basis and the Compliance Officer shall ensure that mechanisms are in place to maintain the anonymity of any Employees or Contractors reporting any matters, recognizing that there may be a point where the individual’s identity may become known or may have to be revealed in certain instances when regulatory authorities are involved.
B. Comment Boxes
The Company will be placing Comment Boxes at both the Bellflower facility and the corporate offices, which will be available for Employees and Contractors to report any suspicious or suspected activity. The Comment Box will be located in the break rooms. Employees and Contractors may also use the Comment Box to report matters on an anonymous basis. The Compliance Officer or his designee is responsible for monitoring the Comment Boxes for purposes of compliance issues and following up on any matters that are reported.
C. Access to Compliance Officer
There will always be an open line of communication between the Compliance Officer and all Employees and Contractors. This means that all Employees and Contractors are not only encouraged, but are required, to contact the Compliance Officer if any questions regarding the implementation of this Plan arise or if any suspected misconduct is observed. The Compliance Officer has an “open door” policy with respect to receiving reports of violations, or suspected violations, of the law, regarding the Company’s policies and procedures in general and with respect to answering employee questions concerning adherence to this Plan.
The reporting of any possible impropriety shall not serve as a basis for any retaliatory actions against the reporting Employee or Contractor. However, any Employee or Contractor who makes an intentionally false statement or otherwise intentionally falsifies or omits information regarding adherence to this Plan and/or other misconduct shall be subject to discipline.
D. Alternative Avenues of Communication
In addition to the Hotline, any Employee or Contractor may report any suspected misconduct or fraud to their immediate supervisor in writing or via e-mail message to compliance@onesmd.com, which shall then be forwarded to the Compliance Officer for review and follow-up.