Compliance

In support of its mission and core values, The Catholic University of America is committed to conducting its activities with the highest integrity and ethical standards, and in compliance with all applicable laws and University policies. However, because the legal and regulatory environment is so complex, it often can be difficult to determine the right course of action. The Compliance and Ethics Program provides resources to use in our daily activities to help determine the right course of action and meet our ethical and legal obligations when acting on behalf of the University. The Program, approved by the University's Board of Trustees, is administered by the Director of Compliance, Ethics, and Privacy, who reports to the Office of the President and the Audit Committee of the Board.

Compliance and Ethics Program Charter

The mission of the University’s Compliance and Ethics Program is to establish and maintain a centralized organizational structure that promotes a culture of ethical behavior, reduces the risk of non-compliance with laws, regulations, and University policies, and supports the University’s mission. The University’s Compliance Officer is responsible for the vision and execution of the Compliance and Ethics Program and will:

• Establish an Executive Compliance Committee consisting of senior officials that will provide regular guidance and input on the implementation of the Compliance and Ethics Program.
• Establish an Enterprise Risk Management Committee to coordinate the ongoing entity-wide assessment of all aspects of the risk environment and in the implementation of initiatives to mitigate risk.
• Assist compliance partners across the University in understanding and fulfilling their compliance responsibilities.
• Communicate and promote the University’s Code of Conduct to the University community.
• Coordinate the development, review, and approval of University policies and communicate and promote those policies to the University community.
• Establish a mechanism for the University community to report compliance concerns anonymously and free from fear of retaliation. Establish a formal process for reviewing reports of potential noncompliance, overseeing corrective action for instances of non-compliance, and documenting outcomes.
• Implement a Compliance Awareness Training program to communicate key compliance risks to the University community, and to communicate and promote the Compliance and Ethics Program resources available to assist members of the University community in addressing those risks.
• Establish ongoing monitoring activities to identify emerging compliance risks, assess the effectiveness of controls to prevent and detect non-compliance, coordinate implementation of new controls and mitigations, and measure the effectiveness of the Compliance and Ethics Program.

The Compliance Officer reports to the Office of the President and to the Audit Committee of the Board of Trustees regarding the status of the Compliance and Ethics Program and ongoing compliance issues and initiatives.