Enforcement and Discipline

The organization’s compliance and ethics program must be promoted and enforced consistently throughout the organization through appropriate (a) incentives to perform in accordance with the compliance program and (b) disciplinary measures for engaging in criminal conduct and for failing to take reasonable steps to prevent or detect criminal conduct.

• Each Ministry of Trinity Health has established policies and procedures outlining disciplinary actions taken for violations of the Code of Conduct, up to and including termination of employment.
• Integrity & Compliance Officers work with their Human Resources departments to ensure that their written colleague disciplinary action policies appropriately consider violations of the Integrity & Compliance Program, the Code of Conduct, and compliance with laws and regulations, and provide for sanctions up to and including termination for the most serious offenses.
• Each Ministry works to ensure that colleagues have knowledge and understanding of the Trinity Health Integrity & Compliance Program and the Code of Conduct and include them in the performance management process.