Noble’s Corporate Compliance Program is one of the key components of our commitment to the highest standards of corporate conduct and ethics. The purpose of Noble’s Corporate Compliance Program is to establish and maintain a system that encourages and promotes ethical business conduct throughout all levels of our organization and to prevent and detect violations of law or Noble policy and procedure. We have tailored Noble’s Corporate Compliance Program to fit the unique environment and characteristics of our organization. In light of Noble’s size and the scope of operations, we rely on several key staff members to share responsibility for implementing our Program. The Vice President of Safety, Risk Management and Compliance, the Director of Human Resources, the VP/CFO, and the President/CEO all have critical roles in the Corporate Compliance Program.
Our Corporate Compliance and Ethics Program encompasses multiple policies, procedures and programmatic activities, as well as the commitment of Noble Leadership and employees. In order to meet our evolving compliance needs, we regularly review and enhance our program.
The Vice President of Safety, Risk Management and Compliance, the Director of Human Resources and the VP/CFO have been designated by Noble to oversee the key elements of the Corporate Compliance Plan. This oversight involves review of policies and procedures relative to Compliance, internal audits relative to Compliance, and establishment and maintenance of a library of regulations and/or access to these regulations, including but not limited to BQIS, CARF, BDDS, SBOH, APS, CPS, Wage and Hour, Workers Comp, GAAP, and HIPAA. These positions report to the President/CEO on matters related to ethics and compliance.
Written Policies and Procedures
The Noble Code of Ethics and Noble Policies and Procedures detail expected employee behavior. Noble also has internal written policies and procedures regarding Safety, Finance, Risk Management, Human Resources and other Administrative and Programmatic issues to guide employees.
Auditing and Monitoring
Internal audits of the billing process and data entry are conducted by designated staff in the Program Service areas and in the Department of Finance. Results of the audits are reported to the Program Directors, the VP/CFO and the President/CEO for recommended action and reviewed by the Agency Corporate Compliance Committee on a quarterly basis. Quality audits of programmatic activities are conducted by the designated Planning Coordinators.
Training and Education
In addition to a formalized New Employee Orientation program, and a formalized ongoing training and education program, the Vice President of Safety, Risk Management and Compliance provides the required annual training on key areas of the Compliance and Ethics Program. All employees must sign an acknowledgement of receipt of the Code of Ethics and the Ethical Code of Service Provision, along with other key policies and procedures.
Noble maintains an “open door” policy with all employees, especially in areas concerning Ethics and Compliance. Any report involving a violation of the Code of Ethics or Compliance Procedures will be investigated by the Vice President of Safety, Risk Management and Compliance and/or the Director of Human Resources. All communication will be kept confidential to the degree possible while conducting the investigation. Findings of the investigation will be presented to the President/CEO and reviewed quarterly by the Agency Corporate Compliance Committee. A member of the Agency Corporate Compliance Committee will report at each meeting of the Audit Committee of the Board a summary of all reports of potential fraud and abuse and any pending legal activity. Employees who violate the Code of Ethics or other Corporate Compliance Procedures will be subject to disciplinary action, up to and including termination.
“No Reprisal” System for Reporting Suspicious Activities
No disciplinary action will be taken against any staff member who reports in good faith an act of wrongdoing including waste, fraud, and abuse or a violation of the Noble Code of Ethics or other agency policy. However, an employee will be subject to disciplinary action if Noble reasonably concludes that the report of wrongdoing was knowingly fabricated to cause harm to someone else or to protect the reporting party or others.
A recorded statement regarding violations can be left 24 hours a day 7 days a week at 1-855-372-8345. If leaving a message, please include as much information as possible to aid in investigation of the allegation. All allegations will be responded to within 48 hours of the report.