procedures, and training; a mechanism for employees to report potential unethical behavior or non-compliance with applicable laws, regulations or Company policy; a requirement that employees cooperate in compliance investigations; periodic risk assessments to help identify key legal and regulatory risks and changes; incentive structures and discipline that promote compliance; appropriate remedial action when an issue is detected, including employee discipline; maintaining required compliance and fraud, waste and abuse programs applicable to our Medicare Part D business; and a leadership team that fosters a positive and ethical culture of open communications.