16.5.3 Framework

(Last Modified on August 14, 2020)

An effective Program is designed to meet the following elements and ensure that:

1. Standards of Conduct: Standards have been adopted that require compliance with applicable law;
2. Oversight by Senior Leadership: High-level personnel have been assigned the authority and responsibility to implement the Program and ensure that the Board of Regents (BOR) is periodically updated on Program status;
3. Accountability of Senior Leadership: Individuals with substantial discretionary authority and/or charged with implementing the Program have not engaged in illegal activities or other conduct inconsistent with an effective compliance program;
4. Training & Awareness: Program requirements and ethical standards are periodically communicated to all employees through effective training and regular communication;
5. Monitoring, Evaluating and Reporting: Effective monitoring is implemented to detect misconduct, evaluate Program effectiveness, and provide a reporting system whereby employees can report misconduct without fear of retribution;
6. Enforcement of Standards: Program standards are enforced through appropriate incentives and sanctions; and,
7. Ongoing Program Improvements: Responses to misconduct are appropriate and reasonable steps are taken to prevent further offenses to include modifying the Program to prevent and detect violations of the law.