Building and managing successful compliance and ethics programs at diverse institutions

Higher education institutions of all sizes face a diverse array of regulations, many with steep penalties for non-compliance.  A successful compliance and ethics program can help institutions mitigate risk, facilitate a positive environment for employees and students alike and promote an institution’s values and integrity. However, colleges and universities encounter a number of challenges in building, managing and maintaining effective compliance and ethics programs.

At a Society of Corporate Compliance and Ethics (SCCE) event, Baker Tilly facilitated a panel of compliance and ethics officers representing three different institutions of varying sizes and structures came together to discuss their experiences. The panelists provided a brief background on their programs and shared both successes and challenges as they helped to build compliance programs for their institutions. Although each may be inherently different, the conversation about these three institutions highlighted a consistent approach with four notable considerations:

• What factors should an institution consider when designing their compliance and ethics program?
• What barriers or constraints could be avoided?
• How can you gain support or buy-in during the compliance program implementation phase?
• How does the institutional profile play a role in the compliance program development process?

Designing and building a compliance and ethics program

Before an institution can begin to contemplate a design for the foundation of a compliance and ethics program, each institution must understand how its dynamic environment and unique culture could impact on the overall program. Conversation among the panelists highlighted some significant considerations that helped them to proactively set the identity for their compliance programs:

• What type of institution do you have: decentralized versus centralized?
• Are the roles, responsibilities and reporting lines well-defined?
• How will the compliance program leadership interact with the institution’s leadership team?
• What relationship will general counsel, risk management, and others have?