Division of Institutional Integrity

The program, led by senior leadership, reflects the university's commitment to integrity, a culture of compliance, and the promotion of high ethical standards. Two organizational groups—the Risk Review Board and the Compliance Partners Working Group—provide oversight and serve as bodies of compliance, ethics, and risk knowledge. The program originates in the Division of Institutional Integrity, which supports compliance activities university-wide.

The Board of Trustees' Audit, Risk, and Compliance Committee provides governing oversight for the program. It advises on reporting quality, risk management, ethical behavior, risk tolerance, and the establishment of a compliant and ethical university culture.

The Chancellor, as the university's executive head, oversees implementation and effectiveness of the program. Senior leadership, including the chancellor's cabinet and vice chancellors, ensures adequate resourcing of compliance functions and promotes a culture of ethical conduct within their areas.

The General Counsel & Director of Institutional Integrity provides administrative oversight to the CCEO and ensures the Office of Compliance and Ethics has sufficient independence, resources, and authority to manage the program effectively.

The CCEO is responsible for managing and coordinating the compliance and ethics program and reports administratively to the General Counsel & Director of Institutional Integrity. The CCEO provides updates to the chancellor and the Audit, Risk, and Compliance Committee, and must have access to necessary resources to carry out the program. The CCEO's responsibilities include:

• Maintaining a professional staff with adequate size, experience, and certifications
• Communicating routinely with the board and chancellor about program effectiveness
• Overseeing and assessing the program for improvements
• Developing and updating the compliance plan

To preserve independence, the CCEO does not maintain any direct functional compliance responsibilities.

The Office of Compliance and Ethics, led by the CCEO, develops a university-wide compliance program that emphasizes awareness, adherence, and collaboration. Core responsibilities include:

• Advising faculty, staff, and administrators on compliance and policy requirements
• Providing university-wide compliance training and awareness programs
• Offering multiple avenues for reporting compliance concerns, including anonymous reporting
• Supporting non-retaliation protections for good-faith reporting
• Collaborating with the Risk Review Board and other officials to identify high-risk areas
• Reviewing and assessing high-risk compliance areas
• Monitoring emerging compliance trends and adopting best practices

Appointed by the chancellor, the Risk Review Board (RRB) advises leadership on risk tolerance and treatment strategies and provides oversight of the compliance and ethics program. It fosters compliance and accountability, supports program development, and promotes institution-wide implementation.

The CCEO has operational responsibility for the program, with support from the RRB, and provides regular updates to the board while seeking its guidance.

The Compliance Partners Working Group is a staff-level committee composed of employees with direct compliance responsibilities. The group supports daily operations, enhances program visibility, and coordinates compliance communication and training.

Membership is determined by RRB recommendations and includes individuals responsible for current high-risk areas as well as key university stakeholders. The group ensures communication and collaboration across academic and administrative units with compliance obligations.