Whereas, Vanderbilt University is committed to the highest standards of ethics, honesty, and integrity and compliance with all applicable laws and regulations; and
Whereas, all members of the Board of Trust, the Chancellor, General Officers, members of the Executive Administration, administrative officers, members of the faculty and staff, and others representing the University are expected to adhere to the highest ethical standards in the discharge of their duties and to comply with all applicable laws and regulations; and
Whereas, a number of compliance activities and programs at Vanderbilt University are decentralized throughout the university, including the Medical Center Compliance Office, the Opportunity Development Center, the Athletic Department, the Department of Environmental Health and Safety, Internal Audit, and the Office of General Counsel, among others; and
Whereas, the Chancellor has determined that it is in the best interest of Vanderbilt University to provide for greater centralized assistance and oversight for compliance efforts and to formalize a comprehensive University compliance program to demonstrate and document the University's commitment to compliance by establishing and maintaining ethical standards, including a Code of Conduct; designating a Compliance Officer and Compliance Liaisons; and instituting procedures to promote compliance through education, monitoring, reporting of violations, and corrective action; and
Whereas, the Executive Committee believes that it is important to document the University's commitment, at the highest level of institutional governance, to an effective compliance program, as evidenced by the Vanderbilt University Compliance Program;
NOW THEREFORE BE IT RESOLVED that the Executive Committee, acting on behalf of the Board of Trust, adopts the Vanderbilt University Compliance Program to evidence and affirm the University's commitment to compliance through the implementation of the Code of Conduct and the appointment of a Compliance Officer and a Committee of Compliance Liaisons with the responsibility for overseeing, monitoring, and assuring the enforcement of the Compliance Program.
BE IT FURTHER RESOLVED that the Executive Committee hereby directs the Chancellor, the Compliance Officer, and the Committee of Compliance Liaisons to implement the Vanderbilt University Compliance Program and to provide regular reports to the Executive Committee, the Audit Committee and the Board of Trust.
Compliance Committees
Vanderbilt University has two compliance committees which have oversight responsibilities for the compliance activities of Vanderbilt and which assist the Vanderbilt community in fulfilling its legal compliance obligations. The Medical Center and Research Compliance Committee provides support for functions related to Medical Center operations and all institution-wide research activities. The Administrative Compliance Committee provides support for University Central operations and activities. The committees oversee the following areas of compliance activity:
- informing, training, and educating the Vanderbilt community about the Standards of Conduct and ethical obligations under those Standards
- monitoring compliance activities, including policies and procedures and training and education programs
- serving as a resource to Vanderbilt on matters of compliance and legal and regulatory changes, and assessing and identifying areas of risk
- maintaining a reporting helpline for compliance matters
- assisting operational units in developing corrective action plans
- recommending and reviewing disciplinary action for violations of the Standards of Conduct
- reporting on compliance activities to the Audit Committee of the Board of Trust through the Compliance Officers
Each Committee is supported and assisted in its oversight responsibilities by a Compliance Officer. Each Compliance Officer is responsible for the day-to-day operations of the Compliance Program. Their responsibilities include employee training on the Standards of Conduct, routine monitoring of compliance activities, assisting with corrective action plans, maintaining a reporting helpline, coordinating interdepartmental compliance efforts, and providing staff support for the Committees' operational activities.