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 and the United States Department of Justice 2019 Guidance, Evaluation of Corporate Compliance Programs.
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 university will be delegated operational responsibility for the compliance program, and the programs will receive adequate stature, funding, and resources. |
Each university 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. |
Each university 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. |
Each university will take reasonable steps to ensure that its compliance program is followed. This includes monitoring efforts to detect misconduct and periodic evaluations of the effectiveness of the compliance program. |
Each university 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 university will respond appropriately and take actions to prevent further similar conduct. |
Each university’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 university will focus not only on regulatory compliance but on a culture that encourages integrity in all aspects. |