Components of an Effective Compliance Program means those components as defined by Chapter 8 of the Guidelines Manual of the U.S. Sentencing Commission and the various guidance documents published by federal government agencies. Those components include, at a minimum:
* written policies; * select and empower the appropriate personnel with authority; * communicate essential information to appropriate audiences; * oversight mechanisms; * system of incentives and disincentives; and * respond to incidents in order to reduce recurrence.