Ethics and compliance program
The Company has a well-established Ethics and Compliance Program (the “Program”) which is led by the Chief Compliance Officer (CCO). Under the leadership of the CCO, the Program establishes an internal committee, the goal of which is to oversee compliance across the organization, recommend policy updates/changes, and drive the compliance culture. The committee is composed of leaders across all areas of the organization.
Certain compliance owners report to the committee annually on compliance topics including but not limited to anti-bribery/anti-corruption, the Open Door process, data security, CMS compliance, Environmental, Health and Safety priorities, postal compliance, records retention, antitrust, and SEC reporting.