1. Leadership & Structure

Compliance Officer. Impel has assigned a Chief Compliance Officer (“CCO”) to serve as the manager of the overall Impel compliance, risk and governance program. Impel is committed to effectively managing risk and ensuring Impel operates with the highest level of integrity. Accordingly, it is the CCO’s responsibility to oversee the development, operation, and on-going effectiveness of Impel’s risk based Comprehensive Compliance Program. Further, the CCO, with support from the Corporate Compliance Committee and senior management, has the ability and authority to effect change within Impel and exercise independent judgment on behalf of the organization.

Corporate Compliance Committee. The Committee is the governing body of the Comprehensive Compliance Program which works closely with the CCO and Impel’s senior leaders to identify and address matters relating to compliance, risk and governance. The Committee is made up of senior leaders who have direct access to the CCO. Impel’s Board of Directors relies on the Committee to make sound, risk-based business decisions which are in the best interest of Impel’s constituents including employees, the healthcare community and the patients it serves.

2. Written Standards

Impel has established written policies, procedures, and guidance documents in compliance with the OIG Guidance and PhRMA Code to ensure employees are acting with the highest ethical standards.

The documents which have been established were developed under the Compliance Officer and Committee members. Impel’s Code of Conduct reemphasizes Impel’s commitment to compliance through its five (5) guiding principles. The Code and additional written standards are available and required for employees to read and adhere to. 

3. Education & Training

All Impel employees are required to be trained on compliance concerns relevant to their job responsibilities. Impel utilizes a variety of training platforms to ensure employees have a strong understanding of Impel’s policies and the laws and regulations which govern the compliance program. Training is conducted during onboarding, with additional annual refreshers as well as on an needed basis.  

4. Internal Lines of Communication

Impel urges all employees to speak up when they know, or suspect of, a violation to Impel’s Code, policies and procedures, or any laws, regulations, or industry codes with which Impel must comply. Impel has an open-door policy and encourages employees to report all known or suspected instances of non-compliance and any questions or concerns. 

Impel does not tolerate retaliation against anyone who raises a concern in good faith. Employees may report compliance concerns or ask questions by contacting a manager, the human resources department, the compliance department, or Impel’s 24-hour hotline. 

• Web intake site: http://impelnp.ethicspoint.com/
• Mobile intake site: http://impelnpmobile.ethicspoint.com/
• Hotline: 844-733-0093

5. Auditing & Monitoring

Impel has established a risk-based approach to auditing and monitoring. Annually, Impel will conduct a compliance risk assessment which will inform the volume and frequency of such monitoring and auditing activities. Activities which are monitored and audited include internal processes and departments as well as external vendor’s compliance to established business rules and best practices. Results on the auditing and monitoring effort will be communicated to Corporate Compliance Committee and senior leaders and will be utilized to effect any necessary change in current compliance policies and processes.

6. Responding to Potential Violations

Impel will evaluate all reports of non-compliance with Impel’s Code of Conduct, policies or procedures or any laws, regulations or industry codes with which Impel must comply in a timely manner and, if appropriate, conduct a prompt, unbiased investigation. The COO, or designee, will investigate all reported possible violations. 

7. Corrective Action Procedures

Impel will take appropriate corrective action which might include coaching, training or discipline up to, in the case of employees, termination of employment to address violations of Impel’s Code of Conduct, policies or procedures or any laws, regulations or industry codes with which Impel must comply. 

Although each case is different, Impel will ensure consistent and appropriate disciplinary actions are taken regardless of the employees role within the company. Impel has detailed an investigations process and progressive disciplinary action system to ensure standard enforcement.