II. PURPOSE OF CORPORATE COMPLIANCE PLAN

A. Introduction

The purpose of this Corporate Compliance Plan is to insure that WNYIL Inc. will maintain its positive reputation and influence in the community by improving the lives of persons in our communities with disabilities and providing better access and cost-effective, quality services in a manner consistent with the Vision and Mission of WNYIL Inc., as summarized above or as otherwise prescribed by its Board of Directors. WNYIL Inc. holds its employees to the highest standards. In our efforts to meet these goals, WNYIL Inc. has established this Corporate Compliance Plan.

B. Mission

The Corporate Compliance Officer of WNYIL Inc. will accomplish this goal by assisting and advising employees, agents and representatives of WNYIL Inc., and to help ensure that WNYIL Inc. is compliant with applicable Federal, State and local laws. In this capacity the Corporate Compliance Officer is committed to providing clear guidelines to train and educate employees, agents and representatives regarding applicable laws, regulations, policies and procedures as they pertain to compliance.

The Corporate Compliance Officer will endeavor to:

1. promote a culture that encourages employees, agents and representatives to conduct activities with integrity and in compliance with all applicable laws, regulations and WNYIL Inc. policies and procedures and to report instances of non-compliance to the Corporate Compliance Officer;

2. educate officers, directors, employees, agents and representatives of WNYIL Inc. concerning the legal risks of certain business practices;

3. encourage WNYIL Inc. Managers to seek appropriate counsel regarding business practices and to conduct those activities within the requirements of the law and ethical standards of conduct for WNYIL Inc. employees; and, to secure compliance with the Federal Sentencing Guidelines.

Corporate Compliance is a partnership with management, to help identify areas of regulatory risk and to help mitigate risk of non-compliance. This partnership enhances management's ability to achieve organizational goals and objectives in a manner consistent with the values of Western New York Independent Living, Inc. The employees of WNYIL Inc. will be expected to be dedicated to the corporation and will act in a diligent, loyal and prudent manner to ensure high standards of creative leadership and fiscal responsibility to collaborate and network with others who share WNYIL Inc.'s values in the provision of programs and services to people with disabilities, advocate on behalf of issues of conscience and human need; and contribute to the preservation and strength of Independent Living.