What’s the responsibility of supervisors?

Supervisors must make reasonable efforts to detect and prevent violations of applicable laws, rules, regulations, and the Code and Standards by anyone subject to their supervision or authority. （发现和阻止违规行为）

Exercise reasonable supervision by establishing and implementing written compliance system and ensuring periodic review on the system.

Can delegate, but should instruct how to supervise, does not relieve them of their supervisory responsibility. （可以转委托他人监管，但必须指示明确且对转委托负责）

If cannot discharge supervisory responsibilities because of the inadequate or absence of a compliance system, should decline in writing to accept supervisory responsibility until adoption. （在inadequate or absence of a compliance system情况下，应拒绝承担监管者责任）

If adopted reasonable procedures and took steps to institute an effective compliance program, may not violate “Responsibility of supervisors” if he does not detect violations that occur despite these efforts. May violate this Code if he knows or should know that the procedures designed to detect and prevent violations are not being followed.

Once knowing a potential violation, supervisor must promptly initiate an investigation to ascertain the extent of the wrongdoing.

Relying on employee’s statements or assurances that the wrongdoing will not recur is not enough.

Reporting the misconduct up the chain of command and warning the employee to cease the activity are also not enough.

Should take steps to ensure that the violation will not be repeated, by placing limits on the employee’s activities or increasing the monitoring of the employee’s activities.