Our Compliance Program

The Federal government provides guidance and direction for establishing and maintaining an effective compliance program in Chapter 8 of the Federal Sentencing Guidelines (the “Guidelines”). The Guidelines prescribe two overarching requirements for the System’s compliance program:

• The System shall “exercise due diligence to prevent and detect criminal conduct.”
• The System shall “otherwise promote an organizational culture that encourages ethical conduct and a commitment to compliance with the law.”

Beyond the two foundational principles, the Guidelines identify seven essential elements for effective compliance programs. The Department of Justice expands and refines those elements in its Evaluation of Corporate Compliance Programs to better reflect the Department’s expectations. The updated elements are set forth below, together with a description of University Ethics and Compliance Office activities associated with each element.

• Risk Assessment
• Policies and Procedures
• Training and Communications
• Confidential Reporting Structure and Investigation Process
• Third Party Management
• Mergers and Acquisitions
• Commitment by Senior and Middle Management
• Autonomy and Resources
• Compensation Structures and Consequence Management
• Continuous Improvement, Periodic Testing, and Review
• Investigation of Misconduct
• Analysis and Remediation of Any Underlying Misconduct

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