Essential Elements of an Effective Compliance Program
监督
- 校董会道德 & 合规小组委员会
- Designated Compliance Officer with daily responsibility
- Compliance Officer has adequate funding, resources and authority
- Compliance Officer access to the Board; annual reports
- Regularly scheduled Compliance Committee Meetings
- Leadership candidates vetted to assure no ethical misconduct
政策及程序
- Code of Conduct is centerpiece of compliance program
- 政策库 accessible by all employees
- Standardized policy review process
教育及培训
- 员工评估 & sign Code of Conduct in orientation / annually
- 年度道德 & Compliance training (employees, trustees, contractors & 代理)
- Targeted training of specific high risk issues
- 补习培训任务
- Assignment tracking; 100% courses completed timely
- Communication of new policies or regulations
开放的沟通方式
- Employees are educated on how to report potential compliance issues: Publicized, accessible hotline; offering confidentiality and anonymity
- Encouragement to report to immediate supervisor
- Employees encouraged to prospectively consult with legal/risk/compliance
- Complainants are briefed on how to receive updates on investigations
- Promotion of the Non-Retaliation Policy
- Exit interviews with departing employees
- Encouragement to report potential compliance issues & 近距离脱靶
执法及纪律
- Compliance requirements are well-publicized
- Fair and consistent across the organization
- Incentives for promotion of a transparent, ethical, compliant culture
审核及监察
- 并发 & 回顾
- Below-target results reported to Compliance Committee
- Below-target results followed-up with
纠正行动计划 - Employee Engagement Surveys include compliance, ethics & 安全问题
- 审计 & Monitoring plan driven by 风险评估 results
应对和预防
- Potential compliance issues are investigated, documented and resolved
- Subject matter experts are consulted
- Root Cause Analysis (RCA) drives the 纠正行动计划 (CAP)
- CAP designed to reduce/eliminate repeat incidents
- Findings are appropriately reported to regulatory agencies
- New hires are vetted via background screening, OIG/GSA exclusion list, etc.
风险评估
- Targeted assessments conducted in response to specific risks
- Broad, all-encompassing assessments performed every 1-3 years
- Steps taken to modify the program in response to repeat violations