R1.1 PROCESS, ESCALATE & MANAGE INCIDENTS
Establish a system for the competent and confidential review, processing, and resolution of noncompliance and issues detected during ongoing monitoring or periodic evaluation of the program.
The system should:
> provide a taxonomy and criteria for categorizing issues
> provide a taxonomy for defining severity of issues
> provide a process to escalate issues when appropriate
> provide a process to refer issues outside the scope of the program
> provide a process to conduct basic investigation and fact-finding
> provide a process to resolve and "close out" issues
> define what types of information should be kept confidential
> define the documents and deliverables that are produced as part of the process
> define how documents and deliverables should be managed and retained
Some issues that arise in the operation of the program may require special investigation and analysis to be fully resolved. Other issues outside the scope of the program should be referred to the appropriate operational units such as Human Resources or Investor Relations. Investigators will determine the facts surrounding or underlying the specific incident, or may investigate the cause of the incident so that changes can be made to the responses in place. Some incidents may give rise to legal requirements for further investigation.
Individuals involved in the process must understand the full scope of potential compliance and ethics-related issues so that they can answer questions and competently process and resolve issues.