Corporate Compliance Plan
Introduction
Family Pride of Northeast Ohio, Inc. is committed to creating and maintaining a work environment of
compliance with federal, state and regional guidelines that facilitates a high quality of professional
mental health service delivery. All employees, students, and volunteers will be trained on the
organization’s Corporate Compliance Plan. Corporate Compliance annual training updates will be
provided to ensure adherence to organization requirements.
Plan
Family Pride has long recognized that our mental health services involve significant legal and ethical
responsibilities. These responsibilities extend not only to our clients, but also many stakeholders,
companies and agencies that we work with, our colleagues and the public at large. We must
demonstrate consistently the way we act with absolute integrity in the way we do our work and the way
we live our lives.
This plan was adopted as a guide for employees’ conduct so that they may fulfill their obligations to
observe the laws and public policies affecting daily business and to deal fairly with clients and
communities where they operate. Employees include interns, volunteers, and regular full-time and parttime employees. The plan provides guidance to ensure that our work is done in an ethical and legal
manner.
For compliance to be effective, it must have cooperation of all employees. The plan contains resources
to help resolve questions about appropriate conduct at work. The plan aids in the identification and
correction of an actual or perceived violations of any applicable rules. The plan imposes a duty upon all
employees to report to the Executive Director any violation of conduct.
The expectation of Family Pride of Northeast Ohio, Inc. is that each and every stakeholder should feel
free without fear of reprisal to communicate concerns to the Executive Director. Any such report will be
maintained in strictest confidentiality to the maximum extent consistent with fair and rigorous
enforcement of the plan.
Failure to observe the organization’s Policies and Procedures can result in serious consequences to the
employee, such as termination and criminal charges. The primary importance of the plan is to ensure
that Family Pride of Northeast Ohio, Inc. maintains its clinical integrity within the service community.
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Directives
The effectiveness of the Corporate Compliance Plan depends upon the leadership efforts at Family Pride
of Northeast Ohio, Inc. Colleagues are obligated to follow the plan, but leaders are expected to set
examples, to be in every respect a model and mentor to employees. Leaders must ensure that staff has
sufficient information and training to comply with laws, regulations, policies and procedures of the
operational manual. Staff must also have access to resolve ethical dilemmas.
Leaders’ Goals are as follows:
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To maintain compliance standards and procedures reasonably designed to reduce the risk of
criminal conduct and other violations of the codes of ethics.
To allow only specific, high level personnel to be assigned the ultimate responsibility for
overseeing the compliance program. The Executive Director has the ultimate responsibility for
the Corporate Compliance Plan. In the event that the executive Director is the focus of the
compliance inquiry, the Chair of the Board of Directors shall act as the convening authority in
the matter.
To take reasonable steps to communicate effectively and achieve compliance with the standards
and procedures for all employees, interns or volunteers.
To utilize auditing systems that are reasonably designed to detect unethical or wrongful
behaviors or criminal conduct by its employees.
To monitor publicized reporting systems for employees, interns and volunteers so that illegal
and unethical conduct by others may be reported to the appropriate authority without fear of
reprisal.
To cooperate with appropriate federal, state, and local authorities investigating a potential
violation of law or unethical behavior. This includes requirement to preserve all evidence, and to
hold intact material related to the alleged offense without altering or destroying it.
Duties of the Compliance Officer (Executive Director)
The Executive Director shall:
 Coordinate and monitor all compliance efforts on a daily basis
 Ensure that all delegations of responsibility under the plan are made to persons reasonably
believed to be morally fit, honest and capable of making necessary judgments.
 Consult with legal counsel to obtain interpretations of any requirements under the plan which
appears unclear.
 Bring to the attention of legal counsel all changes in circumstances, which could reasonably
suggest that the plan should be modified.
 Promptly complete all tasks expressly assigned by the plan.
Training and Education
The Executive Director shall train all staff on the expectations of the plan and distribute the
organization’s policies on professional ethics . All staff will be required to read the plan and sign
acknowledgement that violations may lead to disciplinary action or criminal charges.
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Reporting Potential Violations
Family Pride of Northeast Ohio, Inc. expects employees to report potential violation of the compliance
plan in writing, using the incident report form.
The Executive Director Shall:
 Review each report and notify the appropriate authorities of any allegation of criminal
behaviors.
 Take action, in conjunction with the Chair of the Board of Directors, commensurate with the
gravity of the allegation to determine if the allegation is valid, and what corrective action should
be imposed.
 Oversee all investigations and corrective action plans that should be imposed and provide status
reports to the Chair of the Board of Directors.
Employee Disciplinary Procedures
Violations of Ethics and Corporate Compliance policy shall be managed as follows:
ACTION
DISCIPLINARY ACTION
Oral reprimand to termination
 Negligently providing false or misleading
information to Family Pride of Northeast
Ohio, Inc., government agency, customer
or insurer
 Negligent violation of federal, state, or
local laws
 Failure to report another employee’s
conduct which violates any law, standard
or regulation.
 Failure or refusal to cooperate with Family
Pride of Northeast Ohio, Inc. in a
compliance investigation
 Failure to exercise adequate supervision of
subordinate personnel where such failure
leads to a compliance incident.
 Engage in any other conduct which fails to
comply with the duties and prohibitions,
expressed or implied, set forth in the
Family Pride Corporate Compliance Plan.
 Intentionally providing false or misleading Termination
information to Family Pride, government
agency, customer or insurer
 Intentional violation of any federal, state
or local law.
 Direct retaliation against any employee
who in good faith reports a compliance
issue.
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Business Associates
The Executive Director shall ensure that as Family Pride of Northeast Ohio, Inc. enters into Business
agreements with firms or persons serving as subcontractors; the Business Associate is in compliance
with federal, state and local requirements.
Record Retention
All Corporate Compliance records shall be maintained for at least (7) seven years.
WhistleBlower Procedures:
Reporting Responsibility
This Whistleblower Policy is intended to encourage and enable employees and others to raise serious
concerns internally so that Family Pride can address and correct inappropriate conduct and actions. It is
the responsibility of all board members, officers, employees and volunteers to report concerns about
violations of Family Pride’s code of ethics or suspected violations of law or regulations that governs the
organization’s operations.
No Retaliation
It is contrary to the values of Family Pride of Northeast Ohio, Inc. for anyone to retaliate against any
Board Member, officer, employee or volunteer who in good faith reports an ethics violation, or a
suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected
violation of any regulation governing the operations of Family Pride. An employee who retaliates against
someone who has reported a violation in good faith is subject to discipline up to and including
termination of employment.
Reporting Procedure
Family Pride has an open door policy and suggests that employees share their questions, concerns,
suggestions or complaints with their supervisor. If employees are not comfortable speaking with their
supervisors or are not satisfied with the supervisor’s response, he/she may speak with the Executive
Director.
Supervisors and managers are required to report complaints or concerns about suspected ethical and
legal violations in writing to Family Pride’s Compliance Officer and Executive Director who has the
responsibility to investigate all reported complaints.
Employees with concerns or complaints may also submit their concerns in writing directly to their
supervisor or the Executive Director/Compliance Officer.
Accounting and Auditing Matters
Family Pride of Northeast Ohio’s Executive Director shall immediately notify the Finance Committee of
any concerns or complaint regarding corporate accounting practices, internal controls or auditing and
work with the committee until the matter is resolved.
Acting in Good Faith
Anyone filing a written complaint concerning a violation or suspected violation must be acting in good
faith and have reasonable grounds for believing the information disclosed indicates a violation. Any
allegations that prove not to be substantiated and which prove to have been made maliciously or
knowingly to be false will be viewed as a serious disciplinary offense.
Confidentiality
Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports
of violations or suspected violations will be kept confidential to the extent possible, consistent with the
need to conduct an adequate investigation.
Handling of Reported Violations
The Executive Director/Compliance Officer will notify the person who submitted a complaint and
acknowledge receipt of the reported violation or suspected violation. All reports will be promptly
investigated within (24) twenty-four hours and appropriate corrective action will be taken if warranted
by the investigation.
Legal and administrative consequences for violation of the ethical code of conduct or the Corporate
Compliance Program include suspension, demotion or possibly termination from employment.
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