Section: 4.15
Issued: 12.31.2005
Updated: 04.02.2024
Reviewed: 04.01.2025
Purpose:
The purpose of this policy is to provide guidance on how to respond to government compliance investigations.
Policy Overview:
It is the policy of AHRC NYC to fully cooperate with reasonable requests of government officials regarding a compliance investigation. The purpose of this Policy is to provide a uniform method by which its employees are to respond in the event that any government entity contacts them in connection to a compliance investigation or manner.
Scope:
This policy and procedure applies to all employees of AHRC NYC.
Procedure:
General Procedures
If at any time a compliance investigative demand letter is received by an AHRC NYC employee or agent, the employee or agent must immediately notify the Chief Compliance Officer/VP Corporate Compliance.
The Chief Compliance Officer/VP Corporate Compliance will coordinate AHRC NYC’s response to the government.
No employee or agent should release or copy documents in connection with or in response to a compliance investigative demand letter without the authorization of the Chief Compliance Officer/VP Corporate Compliance.
No employee or agent may remove, alter, create or destroy documents or records including, but not limited to, paper, tape, and computer records, in anticipation of, or during, an investigation or audit.
If an investigator or other government representative appears in person, employees should ask to see and make a copy of their identification and business card. If these materials are unavailable, ask for the person’s name and office, address and telephone number, and identification number. They are to immediately forward the information to the Chief Compliance Officer/VP Corporate Compliance who will then issue additional guidance.