IV. CORPORATE COMPLIANCE PLAN OVERVIEW

A. Responsible Persons

1. Corporate Compliance Officer: The Corporate Compliance Plan is directed and coordinated by Tina Brown, Director of Human Resources, who serves as the Chair of the Corporate Compliance Committee and Corporate Compliance Officer. The Corporate Compliance Officer is responsible for day-to-day operation of the Corporate Compliance Plan, shall report directly to the Executive Director and shall be accountable to the Board of Directors for the implementation of and on-going operations of the Corporate Compliance Plan. The Corporate Compliance Officer will update and report progress to the Corporate Compliance Committee at its regular meetings.

2. Corporate Compliance Committee: The Corporate Compliance Committee consists of members of the Board of Directors, selected individuals from the community, Executive Director, selected members of the Management Team, and the Corporate Compliance Officer. The Committee will:

a. assist the Corporate Compliance Officer in the implementation of the Corporate Compliance Plan;
b. provide strategic direction to the Plan;
c. provide support and feedback for the development of priorities for the Compliance Plan and the implementation of the Compliance Plan at WNYIL Inc. and WNYIL Inc.'s satellite offices;
d. establish priorities for educational programs to be provided as part of the Corporate Compliance Plan; and
e. help identify necessary human and financial resources required for the effective implementation of the Corporate Compliance Plan.

3. Corporate Compliance Team: A Corporate Compliance Team shall be created and will consist of members of the Management Team. The Corporate Compliance Team will have the responsibility of assisting the Corporate Compliance Officer in the implementation of the Corporate Compliance Plan. The Team shall provide support and feedback for the development of priorities for the Compliance Plan and the implementation of the Compliance Plan at WNYIL Inc. and WNYIL Inc. Satellite Offices. In addition, the Committee shall establish priorities for educational programs to be provided as part of the Corporate Compliance Plan and to help identify necessary human and financial resources required for the effective implementation of the Compliance Plan.

4. Legal Representative: The Corporate Compliance Officer shall work cooperatively with the Robert W. Patterson, Esq., outside legal counsel, in the development and implementation of the Compliance Plan. Counsel will:

a. provide legal counsel and support to the Corporate Compliance Officer;
b. actively participate in the training and educational programs that are implemented as a part of the Compliance Plan; and
c. where requested, investigate complaints and reports of violations of the Plan.

B. Corporate Compliance Team

Tina Brown
Corporate Compliance Officer/Director of Human Resources
WNYIL Inc.
3108 Main Street
Buffalo NY 14214
(716) 836-0822 extension 102

Catherine Colicchia
Director of Transportation
WNYIL Inc.
3108 Main Street
Buffalo NY 14214
(716) 836-0822 extension 150

Crystal Jackson
Director of Independent Living Center
WNYIL Inc.
3108 Main Street
Buffalo, NY 14214
(716) 836-0822 extension 115

Maura Kelley
Director of Mental Health Peer Connection
WNYIL Inc.
3108 Main Street
Buffalo, NY 14214
(716) 836-0822 extension 162

Sarah Lanzo
Director of Independent Living of Niagara County
ILNC
746 Portage Rd.
Niagara Falls NY 14301
(716) 284-4131 extension 209

Becky K. Usiak
Director of Intra-Agency Operations
3108 Main Street
Buffalo NY 14214
(716) 836-0822 ext 128

Towana Vance
Director of Taking Control
3108 Main Street
Buffalo NY 14214
(716) 836-0822 ext 151

Members of the Corporate Compliance Committee of the Board of Directors:

Tina Brown
Corporate Compliance Officer
WNYIL Inc.
3108 Main Street
Buffalo NY 14214
(716) 836-0822 extension 102

Dennis Kessel
WNYIL Inc.
3108 Main Street
Buffalo NY 14214
(716) 836-0822 extension 104

Paul Beakman
WNYIL Inc.
3108 Main Street
Buffalo NY 14214
(716) 836-0822 extension 104

Raymond Reichert
WNYIL Inc.
3108 Main Street
Buffalo NY 14214
(716) 836-0822 extension 104

Sue Sehl
WNYIL Inc.
3108 Main Street
Buffalo NY 14214
(716) 836-0822 extension 104

Douglas J. Usiak
Executive Director
WNYIL
3108 Main Street
Buffalo, NY 14214
(716) 836-0822 ext 117

C. Principle Components

The Corporate Compliance Plan shall include the following principle components:

1. Education and training of employees, representatives and agents to ensure compliance with the Corporate Compliance Plan, as is further described in Part V.

2. A Code of Conduct which shall govern the proper conduct of WNYIL Inc. directors, officers, employees, agents and representatives and require all such individuals to comply with the ethical and legal standards outlined in this Compliance Plan. The current Code of Conduct is set forth in Exhibit A to this Plan.

3. Audit and monitoring systems designed to detect ethical or legal violations, including appropriate internal audits and surveys to verify adherence to and awareness of WNYIL Inc.'s ethics and compliance policies and procedures, as is further described in Part VI.

4. A reporting system whereby employees may report suspected violations of standards for ethical and legal conduct, as is further described in Part VII.

5. Procedures for investigating and, if appropriate, correcting and reporting violations of the Plan, as is further described in Part VIII.

6. A Fraud and Abuse Compliance Policy, containing detailed standards for preventing, investigating and correcting fraud and abuse, set forth in Part IX.