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• Clear and accessible policies and procedures to prevent and detect criminal conduct.
• Leadership delegates responsibility to, and supports, appropriate staff to ensure that the program is implemented and effective.
• Due diligence, including background checks, prevents individuals who have engaged in conduct inconsistent with the program from being given similar responsibilities.
• Routinely communicate policies, procedures, including all mandatory reporting, and other aspects of the program to leadership, employees, and agents, including volunteers, by providing information, resources, and training.
• Promote and enforce program through appropriate incentives and disciplinary measures for criminal conduct and for failing to prevent or detect criminal conduct.
• Provides a system which facilitates notifications including:
  • Confidentially processes notifications from -
    • Employees
    • Clients/customers/members/participants/ ...
    • All others
  • Actual and potential violations of -
    • Important policies
    • Law
    • Safety
    • Security
  • Facilitates & documents all mandatory reporting.
  • Comments and feedback.
  • Hosted and managed by independent third party.
  • Visible and easily accessible.
  • Simple to use.
  • Cloaks/protects the identity of notifiers.
  • Notifiers can check status.
  • Confidential, two-way messaging.
  • Data can neither be hacked nor destroyed.