Section: 4.15
Issued: 12.31.2005
Updated: 03.20.2023
Purpose:
The purpose of this policy is to provide guidance on how to respond to government investigations.
Policy Overview:
It is the policy of AHRC NYC to fully cooperate with reasonable requests of government officials. This policy will provide a uniform method by which its employees are to respond in the event that any government employee (Federal or state) contacts an AHRC NYC employee, either during office hours or at home, for information regarding AHRC NYC or any AHRC NYC entity or affiliated person.
Scope:
This policy and procedure applies to all employees of AHRC NYC and its subsidiary corporations.
Procedure:
General Procedures
If at any time an investigative demand letter, subpoena, or search warrant is received by an AHRC NYC employee, the employee must immediately notify the vice president of Corporate Compliance.
The vice president of Corporate Compliance will coordinate AHRC NYC’s response to the government.
No employee should release or copy documents in connection with or in response to an investigative demand letter, subpoena, or search warrant without the authorization of the vice president of Corporate Compliance.
No employee 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. Call the government representative’s office to confirm their identity and authority. If more than one representative appears, determine which representative is in charge and ask for their identifying information.