Corporate Compliance
Corporate Compliance Policy
Corporate
Compliance is a system of rules and standards that the Kennedy Child
Study Center (the Center) has established to ensure that all employees
adhere to the same high ethical and legal standards in our daily
relationships with the children and families enrolled in agency
programs, vendors, insurance companies, private contributors and
government agencies.
It
has been and continues to be the policy of the Kennedy Child Study
Center to comply with all applicable federal, state and local laws and
regulations, and payer requirements. It is also the Center’s policy to
adhere to the Code of Conduct as adopted by the Board of Directors and
implemented by the Executive Director and the Compliance Committee.
The
Center has always been and remains committed to its responsibility to
conduct its business affairs with integrity based on sound ethical and
moral standards. The Center holds its employees, contracted
practitioners, and vendors to these standards, and it is committed to
maintaining and measuring the effectiveness of compliance policies and
standards through monitoring and auditing systems reasonably designed
to detect noncompliance by its employees.
All
employees, contracted practitioners, and regular vendors must
acknowledge that it is their responsibility to report any instances of
suspected or known noncompliance to their immediate supervisor, the
Corporate Compliance Officer, or the Compliance Help Line.
Reports
may be made anonymously without fear of retaliation or retribution.
Failure to report known noncompliance or making reports which are not
in good faith will be grounds for disciplinary action, up to and
including termination. Reports related to sexual or other harassment or
other workplace-oriented issues will be referred to Human Resources.
Employees
and independent contractors who, upon investigation, are found to have
committed violations of applicable laws and regulations, the Corporate
Compliance Program, the Code of Ethics or other Center policies and
procedures, will be subject to appropriate disciplinary action, up to
and including termination.
Every
employee has an obligation to refuse to participate in any wrongful
course of action and to report the actions according to the procedure
listed below. The identity of reporters will be safeguarded to the
fullest extent possible and will be protected against reprisal.
The
Center’s compliance standards, policies and procedures are described in
the Corporate Compliance Manual, as well as in the Center’s Finance and
Accounting Manual and Employee Handbook. Anyone wishing to have access
to the Center’s entire Corporate Compliance Manual, Code of Conduct or
Whistle Blower Policy should contact Joan Flood Dwyer, the Center’s
Corporate Compliance Officer.
To report concerns please contact:
Joan Flood Dwyer
Corporate Compliance Officer
212-988-9500 x 280 or jdwyer@kenchild.org
or
To make an anonymous report,
call the Center’s Hot Line number at
212-988-9500, x 333 |
