Contract analysis

1. Written policies, procedures, and standards of conduct that articulate the organization's commitment to compliance and set forth specific expectations for conduct;

2. Designation of a compliance officer and a compliance committee charged with operating and monitoring the compliance program;

3. Effective training and education for all affected personnel regarding compliance obligations and the organization's compliance policies;

4. Effective lines of communication between the compliance officer and all employees, including a mechanism for reporting suspected compliance violations without fear of retaliation;

5. Well-publicized disciplinary guidelines for enforcement of compliance standards;

6. An effective system for routine monitoring, auditing, and identification of compliance risks, including a mechanism for evaluating the effectiveness of the compliance program; and

7. Prompt response to detected offenses, including the development and implementation of corrective action plans and, where appropriate, voluntary self-disclosure and repayment. This Manual addresses each of these seven elements as applied to AHT's specific operations, organizational structure, and risk profile. The sections of this Manual that correspond to each element are identified in the following table: 3.2 Boa