About the Ethics and Compliance Program
Standards of Conduct and Procedures
Standards of conduct set out in The Texas A&M University System (system) policies and regulations are designed to communicate to all system employees an expectation and requirement of ethical conduct and compliance with all applicable laws, policies, regulations, rules and procedures.
Standards of conduct provide guidelines for business decision-making and behavior. System policies and regulations in addition to Tarleton rules and procedures are the official standards for university operations. Policies and procedures provide the framework within which all employees are expected to operate and apply to all university employees.
Maintaining Tarleton rules and procedures that address changing university needs and regulatory requirements is an ongoing process. All areas of the university are involved in their development. The approval and review processes are coordinated by the University Compliance Office.
Oversight and Governance
The Campus Ethics and Compliance Committee (CECC) reports to the Executive Leadership Cabinet. The CECC is composed of senior campus leadership representing the various areas of campus compliance risks and is chaired by the university's appointed institutional compliance officer. The charge of the CECC is:
- to develop an Ethics and Compliance Program that provides effective processes to identify and manage key risks, including the risk of non-compliance with state and federal laws and regulations and system and university policies, regulations, rules and procedures. The program will address the elements of an effective compliance program as detailed in the Federal Sentencing Guidelines;
- to engage a risk-based Compliance Annual Work Plan that identifies key areas of compliance risks facing Tarleton and establishes a mitigation and monitoring plan for those risks;
- to communicate instances of non-compliance to the institutional compliance officer;
- to follow-up on compliance review findings to ensure appropriate corrective actions have been taken; and
- to continuously assess the effectiveness of institutional compliance activities including the effectiveness of the group, itself.
The CECC will communicate instances of actual or suspected non-compliance to the institutional compliance officer as soon as possible after discovering or receiving possible violation report so that a review can be conducted and/or a corrective action plan implemented.
The CECC meets quarterly to address risk mitigation, to provide appropriate resources for compliance and to ensure appropriate action for noncompliance issues brought to its attention. The institutional compliance officer submits a quarterly report to the Executive Leadership Cabinet and to the system Ethics and Compliance Office which provides updates on the annual work plan and compliance activities and processes.
Education and Communication
In order to "do the right thing," all Tarleton employees need a clear understanding of relevant compliance responsibilities and consequences for violations. A variety of strategies will be used for education and communication such as delivering training presentations and/or modules, posting a Tarleton Compliance Calendar, conducting campus surveys to assess the current knowledge of compliance issues and publishing a quarterly newsletter that highlights compliance issues and provides updates to policies and procedures. This list of strategies is not all-inclusive. Through the use of surveys and input from campus leadership, compliance education and communication can be targeted to meet specific needs.
Monitoring and Reporting
Employees are responsible for identifying and reporting risk and compliance concerns to management. Management is responsible for assessing compliance and safety risks, monitoring internal controls, reporting concerns, and taking corrective action as needed. The Ethics and Compliance Program supports management through internal reviews; assessments; monitoring of processes; compliance with system policies/regulations and university rules and procedures; and reviewing internal controls that facilitate compliance with internal reviews and assessments, monitoring of processes, and reviewing internal controls that facilitate compliance with internal and external regulations, policies, and rules. Reviews may be selected based on significant issues, risks, and other concerns identified by the CECC, university leadership, and/or system, state and federal audits. Review findings, periodic reports, presentations and briefings apprise the Executive Cabinet of significant compliance risk areas and the status of program activities. University leadership supports all activities to expand awareness and facilitate responses to important compliance issues. In cases where noncompliance is found, corrective action plans are developed and communicated. Ultimately, the university leadership is responsible for compliance with all applicable laws, regulations, policies, and other directives.
Each member of the Tarleton community is expected to demonstrate workplace integrity and compliance with legal and regulatory requirements - to do the right thing. This responsibility involves asking questions when there is uncertainty about the correct action for a particular situation, and reporting campus compliance risks and concerns.
The University Compliance Office website includes a mechanism where individuals may submit ethics and compliance questions and/or anonymously report compliance concerns [University Compliance Help and Reporting button]. Also, the system-hosted Risk, Fraud and Misconduct Hotline is available to individuals to report wrongdoing anonymously without fear of retaliation.
Enforcement and Discipline
The responsibility for adhering to all laws, regulations, system policies and regulations and university rules and procedures rests on each member of the university community. Failure to comply with these may result in disciplinary action in accordance with system policies and regulations.
Response and Prevention
Response addresses the actions that are taken to ensure that compliance violations are remedied. Prevention addresses the steps that are taken to prevent similar compliance violations from occurring in the future.
The university will provide quick response to any compliance violation. When necessary, the institutional compliance officer will work with the appropriate department head to ensure that an action/correction plan is in place to address the identified compliance violation and to prevent future violations. Depending on the level of the infraction, consultation with the system Office of General Counsel and/or the system ethics and compliance officer may be required. A summary of compliance violations and corrective actions will be included in quarterly reports to the Executive Cabinet and the system Ethics and Compliance Office.