The National Academies of Sciences, Engineering, and Medicine

Action Collaborative on Preventing Sexual Harassment in Higher Education

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Message from President Cross

Rethinking the Hiring Process

University of Wisconsin System takes a stand against sexual misconduct by changing policies.

“It’s cutting-edge and I think the other systems are looking at us in Wisconsin, leading the charge,”

~ John Robert Behling

President of the University of Wisconsin System Board of Regents, 2017 – 2019

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UW System Policies

Primary governance policies and procedures for UW System

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The Office of Compliance and Integrity was established to support compliance efforts across UW System, including Clery Act, Title IX,  Protection of Minors, Ethics, Public Records, and Records Management. The Office of Compliance and Integrity serves to support UW System institutions to uphold applicable laws, regulations, and policies while helping build a culture which moves beyond regulatory compliance and promotes integrity across UW System.

Governance

The UW System compliance framework was established through collaboration with the UW System Compliance Officer Working Group and approved by the UWSA Risk and Compliance Council and the Audit Committee of the Board of Regents in 2019. The six elements that guide the framework of the UW System compliance structure were selected based on a review of external sources, primarily the Federal Sentencing Guidelines of the U.S. Sentencing Commission[1] and the United States Department of Justice 2019 Guidance, Evaluation of Corporate Compliance Programs.[2]

Six Key Guiding Elements of the UW System Compliance Framework

  1. High Level Oversight / Tone at the Top- The Board of Regents and senior leadership for UW System will be knowledgeable about the content and operation of the UW System compliance program. The “tone at the top” will be visible, strong, and explicit. Specific individuals at each institution will be delegated operational responsibility for the compliance program, and the programs will receive adequate stature, funding, and resources.
  2. Written Policies and Procedures- Each institution should establish standards and procedures to prevent and detect misconduct. The procedures should be in writing, easy to locate, understandable, and reviewed and updated regularly.
  3. Communication, Education, and Training- Each institution should take reasonable steps to communicate periodically and in a practical manner its standards and procedures by conducting effective training programs and otherwise disseminating information appropriate to individual roles and responsibilities.
  4. Monitoring and Auditing- Each institution will take reasonable steps to ensure that its compliance program is followed. This includes monitoring efforts to detect misconduct and periodic evaluation of the effectiveness of the compliance program.
  5. Reporting and Investigation – Each institution will take reasonable steps to publicize a system whereby the employees may report concerns or seek guidance regarding potential or actual misconduct without fear of retaliation. This includes the ability to report anonymously. After misconduct has been detected, the institution will respond appropriately and take actions to prevent further similar conduct.
  6. Culture of Accountability, Ethics, and Integrity- Each institution’s compliance program should be promoted and enforced consistently through well-publicized guidelines that provide incentives to support the program and disciplinary measures for engaging in misconduct or failing to take reasonable steps to prevent or detect misconduct. Each institution will focus not only on regulatory compliance but on a culture that encourages integrity in all aspects.

 

[1] U.S. Sentencing Guidelines Manual § 8B2.1 (U.S. Sentencing Comm’n 2018).

[2] Criminal Div., U.S. Dep’t of Justice, Evaluation of Corporate Compliance Programs (2019).


 

Partnership between Enterprise Risk Management, Compliance, and Internal Audit

Three Lines of Defense pdf

UW System Compliance Governance Structure

UW System Compliance Governance Diagram pdf

Disclaimer

The information presented on this website is for informational purposes only and nothing on this website should be construed or relied upon as legal advice. The OGC or UW-Madison or UW-Milwaukee legal offices should be consulted regarding the specific facts and circumstances associated with any legal matter.