COMPLIANCE CHARTER G A R Y N I M A X A S S I S T A N T V I C E P R E S I D E N T F O R C O M P L I A N C E
U.S. Federal Sentencing Guidelines The compliance program’s objective is to establish and promote standards that meet these seven elements of an effective compliance program: • Standards and procedures to prevent/detect criminal activity • Oversight by high-level personnel, with reports to the board • Due care in delegating substantial discretionary authority • Effective communication and training • Systems for monitoring, auditing and reporting suspected wrong-doing without fear of reprisal • Consistent enforcement of compliance standards • Reasonable steps to respond to and prevent offenses 2
3
Compliance Charter • Summarizes the mission of the compliance function for the University, including its Medical Center, and how the seven elements of an effective compliance program are met • Incorporates best practices by using elements of compliance charters from other universities • Specifies the professional standards and responsibilities related to the compliance program, and the interaction between the compliance, audit, and ERM functions 4
Recommend
More recommend