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Compliance & Ethics Program

What is a compliance & ethics program?

W&M's compliance and ethics program is the sum of many parts: the policies and other controls designed to ensure W&M satisfies its compliance obligations, the efforts of employees to implement these policies and controls, and the mechanisms for detecting and remedying problems. A compliance program also can be thought of as a collection of rules and standards and the ways we try to ensure these rules are followed and standards are met.

The compliance program is endorsed and defined by the Charter approved by the Board of Visitors. The Chief Compliance Officer has overall responsibility for the program.

The College of William & Mary in Virginia
Compliance Program Charter

The College of William & Mary, including the Virginia Institute of Marine Sciences (the university), is committed to lawful and ethical behavior in all of the university's activities. The compliance and ethics program of William & Mary is dedicated to this goal. This charter defines and specifies key aspects of the compliance and ethics program.

The Audit and Compliance Committee of the Board of Visitors provides oversight of the compliance and ethics program. The Committee:

  • Approves the Compliance Program Charter.
  • Promotes and supports a university-wide culture of ethical and lawful conduct.
  • Ensures adequate resources and appropriate authority are provided to the compliance program.
  • Provides oversight of significant compliance and ethics issues and risks.
  • Receives reports from the Chief Compliance Officer regarding reports and investigations as well as the overall effectiveness of the compliance and ethics program.

The Chief Compliance Officer has overall responsibility for the compliance and ethics program and the Office of Compliance and Equity (Compliance Office).[1]  The Chief Compliance Officer reports to the President and has direct access to the Audit and Compliance Committee.

The Compliance Office is charged with developing and coordinating implementation of a compliance and ethics program meeting federal guidelines. The Office:

  • Ensures that the university has policies and procedures reasonably designed to satisfy legal obligations and prevent misconduct, and systems for detecting misconduct.
  • Manages the policy program and promotes awareness of the university's Code of Ethics and other institutional values, regulations, and policies.
  • Identifies and addresses, with management, significant compliance risks and violations. Participates in strategic planning and risk management programs.
  • Investigates reported or suspected compliance or ethical violations[2] and, with University Counsel, coordinates the university's response to regulatory investigations and inquiries. The Compliance Office, with accountability for confidentiality and safeguarding records and information, is authorized full access to university records, physical properties, and personnel pertinent to carrying out investigations.
  • Reports significant ethics and compliance activities and issues to the university's executive management and reports on the effectiveness of the compliance and ethics program to the Audit and Compliance Committee.

University leadership is responsible for promoting a strong culture of compliance and ethics throughout the organization, with shared values and a commitment to the Code of Ethics. Executive employees and other managers:

  • Align operational activities and strategic plans with the university's core values (Code of Ethics).
  • Create a "speak up" culture, where employees are encouraged to come forward with concerns and retaliation is not tolerated.
  • Demonstrate a commitment to integrity.
  • Ensure that misconduct is addressed through appropriate disciplinary action and remedial measures.

All members of the university community share responsibility for maintaining an environment of accountability and integrity.

  • Supervisors must ensure that employees have the knowledge and skills to fulfill their obligations. Supervisors must appropriately address or elevate reported violations or similar issues, including by preventing retaliation.
  • All employees must obey the laws, regulations, and policies applicable to their university activities, and report illegal or unethical action that comes to their attention.[3] All employees are expected to cooperate with investigations.
  • The university will not tolerate any form of retaliation against a member of the university community for reporting illegal or unethical conduct, as provided in the Whistleblower Policy.

Approved, Board of Visitors of the College of William & Mary, February 10, 2017.

[1] Federal regulations require that a specific, "high-level" individual be given "overall responsibility" for the compliance and ethics program.

[2] Reported or suspected violations may be investigated by other individuals, committees, or offices, under university policies or procedures. For example, reports of research misconduct by a faculty member are investigated in accordance with the Faculty Handbook.

[3] Code of Ethics of the College of William & Mary.