1.18 ISU Compliance Program Policy

Mission Statement: To promote and support a culture at the University which cultivates compliance awareness into the daily activities of the University and encourages all members of the University community to conduct University business with the highest standards of honesty and integrity.

Background: The University operates in an increasingly complex environment with numerous laws and regulations that govern our activities as an institution and many agencies monitoring our activities. The penalties for violating laws and regulations, even when they involve a good faith effort, are often severe. Therefore, we emphasize compliance with laws and regulations, personal accountability, and ethics in performing our duties at the University.

The Compliance Program's principal functions include:
• Coordinating, monitoring, and, when appropriate, improving, the University's various compliance functions; and
• Ensuring the institutional perspective is always present when managing the University's compliance risks.

The Compliance Program's goals are:

• Building on existing University structures, improve the University's coordination, dissemination and communication of compliance information, and identify gaps in compliance;
• Fostering an organizational culture that encourages a commitment to compliance and ethical conduct in the University community and improving communication within the University regarding compliance challenges;
• Assisting the University community with compliance related processes, identifying emerging compliance trends, providing compliance support activities, and coordinating and managing compliance risks;
• Promoting compliance awareness by assisting in the development and delivery of compliance related training; and
• Serving as a resource for the University community by providing the means for the community to obtain assistance with compliance issues and report concerns related to compliance.

Applicability: The Illinois State University community is responsible for maintaining the highest ethical standards and complying with applicable laws and regulations.

Roles and Responsibilities: The following is a description of the roles and responsibilities for each member of the University community in building and developing the Compliance Program.

Compliance Committee: This group is comprised of representatives from the Office of the President, from each VP area, and faculty representative(s) that will meet periodically to:

1. Review existing University policies and procedures to ensure they are based on University values and policies and reflect the University's commitment to good practices and following the law;
2. Identify priorities for the Compliance Program that support the University's mission using risk management principles;
3. Recommend activities to promote an organizational culture that encourages a commitment to compliance and ethical conduct;
4. Discuss emerging compliance issues and identify University-wide coordination issues;
5. Assess and report progress regarding key compliance areas;
6. Provide guidance and feedback regarding compliance program implementation items;
7. Exercise reasonable oversight of the Compliance Program and provide timely reports on the Compliance Program and particular compliance matters to the Vice Presidents; and
8. Make recommendations to improve the Compliance Program, including coordination with Compliance Partners.
9. Assist supervisors and members of the University community to become familiar with compliance responsibilities when performing his/her University business or obligations.

Compliance Partners: A Compliance Partner is the University personnel assigned with the day-to-day responsibility for managing compliance activities for a particular compliance area as noted on the Compliance Matrix on the Compliance Program website. Compliance Partners will:
1. Recommend institutional policies and develop procedures relevant to their compliance areas that are designed to ensure the University complies with applicable laws, regulations, University policies, and other applicable standards;
2. Ensure training and support is available to University community members regarding compliance responsibilities;
3. Monitor compliance efforts and emerging issues within their compliance area and develop appropriate plans to address such issues;
4. Respond to reports of potential non-compliance and ensure corrective measures are implemented; and
5. Coordinate with the Compliance Committee, the Office of the General Counsel, Internal Audit, and other University departments on University compliance priorities.

Office of General Counsel / Internal Audit Offices/Ethics Office/Equal Opportunity and Access: These Offices will:
1. Serve as resources for the Compliance Committee, Compliance Partners, and other University community members engaged in compliance activities;
2. Assist Compliance Partners to identify emerging compliance issues;
3. Develop institutional compliance program elements including: a Compliance Program Website, a mechanism for University community members to report non-compliance, and a system where University community members can request and receive compliance guidance;
4. Identify policy concerns that impede compliance and support Compliance Partners to address such issues in a timely manner; and
5. Evaluate the effectiveness of the Compliance Program, including auditing the high-risk compliance areas.

University Community: The members of the University community should be accountable to ensure that they are aware of and operate in compliance with applicable laws, policies, and other standards, and report incidents of possible non-compliance or concerns.