Purpose
The purpose of the 麻豆女郎 Compliance Office Charter (Charter) is to:
- Identify the authority, mission, value, scope, and responsibilities of the Compliance and Ethics Office (Compliance Office) at 麻豆女郎 (麻豆女郎 or University);
- Ensure that the Compliance Office adheres to a code of ethics, maintains organizational independence and has unrestricted access to University records and personnel; and
- Provide for a periodic review of and changes to the Charter, as necessary and appropriate.
Authority
Florida Board of Governors (BOG) Regulation 4.003, State University System Compliance and Ethics Programs, requires each board of trustees to implement a university-wide compliance and ethics program that promotes ethical conduct and maximizes compliance with applicable laws, rules, regulations, and policies. The BOG Regulation 4.003 also requires 麻豆女郎 to designate a chief compliance officer, who shall be governed by a Charter approved by the board of trustees.
Mission and Vision
The mission of 麻豆女郎鈥檚 compliance and ethics program is to assist the university in achieving its financial, operational and strategic goals while promoting an organizational culture that encourages compliance with all institutional policies as well as federal and state laws and regulations.
麻豆女郎鈥檚 Compliance Office provides an organizational structure and range of services that:
- Support the University鈥檚 mission, vision and values;
- Promote a culture of compliance and ethical behavior;
- Encourage a commitment to compliance with laws, rules, regulations, and policies;
- Reduce the risk of non-compliance; and
- Add value to and improve 麻豆女郎鈥檚 operations.
The scope of work for the Compliance Office is to:
- Encourage and promote ethical behavior, a culture of integrity, and a commitment to compliance;
- Communicate information about compliance-related laws, rules, regulations, and policies;
- Respond to employees inquiring about compliance and ethics-related matters and assist employees with understanding University policies and regulations pertaining to compliance;
- Conduct ongoing oversight of compliance with laws, rules, regulations, and policies;
- Administer and coordinate a compliance and ethics training program;
- Identify and evaluate risks to the University and ensure that those risks are being properly managed by the appropriate University components;
- Chair a compliance committee to collaborate with and provide proactive guidance for University employees responsible for compliance functions;
- Provide University stakeholders with a reporting mechanism to bring forward good-faith concerns of wrongdoing without fear of retaliation;
- Handle or oversee compliance-related investigations or reviews; and
- Review and advise management on compliance-related issues.
The responsibilities of the Compliance Office are to:
- Develop and direct the University鈥檚 compliance function;
- Provide leadership, oversight, and expert advice to ensure appropriate development, interpretation, and implementation of the University鈥檚 policies and regulations pertaining to compliance;
- Establish, review, or revise policies and procedures to encourage ethical conduct and compliance with laws and regulations;
- Engage in monitoring activities or risk assessments to prevent and detect misconduct or violations of institutional policies or applicable laws and regulations;
- Develop communication to promote compliance with 麻豆女郎鈥檚 policies and procedures;
- Develop or implement compliance training or awareness programs;
- Develop or provide compliance and ethics training to the 麻豆女郎 Board of Trustees, the President and the Executive Leadership Team, and employees to assist the University community members with understanding compliance issues and infusing an ethical framework into the fabric of the University;
- Establish and maintain a mechanism for individuals to report potential violations of University policies, laws, or regulations without fear of retaliation;
- Ensure that managers or supervisors responsible for compliance functions within the University, (such as athletics, the designated covered components (for purposes of the HIPAA regulations), environmental health and safety, finance, procurement, financial aid, and research) coordinate and communicate program matters of substantial import with the Chief Compliance Officer;
- Oversee the processing of internal complaints and refer concerns to an appropriate University office for review and disposition (such as General Counsel, Internal Audit or Human Resources);
- Respond to detected offenses, assist the University in developing corrective action plans, and report findings to appropriate administration officials;
- Oversee the process for outside activity reporting and provide integrity review and guidance on conflicts of interest and conflicts of commitment;
- Serve as the research integrity office for foreign influence and provide guidance, leadership and support on matters pertaining to foreign influence concerns;
- Bring all compliance-related matters of substantial import and all credible evidence of misconduct, including criminal conduct, to the attention of the President and the Chair of the Audit and Compliance Committee of 麻豆女郎鈥檚 Board of Trustees, as well as the Board of Governors鈥� Inspector General, as applicable;
- Prepare an annual report for approval by the President, Chair of the Audit and Compliance Committee, and the 麻豆女郎 Board of Trustees regarding activities, accomplishments and the effectiveness of the compliance and ethics program, and provide a copy of the approved annual report to the Board of Governors;
- Ensure that reviews of the compliance and ethics program are conducted to determine its effectiveness at least once in each successive five-year period; and
- Perform other activities consistent with this Charter, as deemed necessary by the President or Chair of the Audit and Compliance Committee of the 麻豆女郎 Board of Trustees.
Professional Standards
麻豆女郎鈥檚 Compliance and Ethics Program shall be implemented consistent with the Code of Ethics for Public Officers and Employees codified in the Florida Statutes at Title X, Chapter 112, Part III, the Federal Sentencing Guidelines, and Board of Governors Regulation 4.003, State University System Compliance and Ethics Programs. The Chief Compliance Officer shall also follow the Code of Ethics of any relevant professional organization to which he or she may belong.
Independence and Reporting
To ensure the impartial and unbiased judgment essential to the proper conduct of the compliance function, the Chief Compliance Officer is organizationally independent of the employees and managers who seek the advice and assistance of the Compliance Office. The Chief Compliance Officer reports functionally to the Chair of the Audit and Compliance Committee of the 麻豆女郎 Board of Trustees and administratively to the President.
Access
The Chief Compliance Officer shall have full, free and unrestricted access to all University information, documents, records, and personnel necessary to carry out the duties and responsibilities of the Compliance Office.
Periodic Assessment
The Chief Compliance Officer shall review the Charter at least once every three years for consistency with applicable Board of Governors and 麻豆女郎 regulations and policies, professional standards, and best practices. The Chief Compliance Officer shall make revisions to the Charter as appropriate.
Adoption of Charter
The Audit and Compliance Committee of the 麻豆女郎 Board of Trustees adopted this Charter on February 20, 2018; renewed without changes on February 16, 2021; amended on November 19, 2024.
1. Purpose
The primary purpose of the Audit and Compliance Committee is to assist the 麻豆女郎 (University) Board of Trustees in fulfilling its statutory, fiduciary and oversight responsibilities relating to:
2. Composition
The Chair and members serving on the Audit and Compliance Committee are appointed and removed by the Chair of the University Board of Trustees. The members will be free from any financial, family or other material personal relationship that would impair his or her independence from management of the University. Each member of the Committee should be financially literate and, if possible, at least one member should be a financial expert. 鈥淔inancial literacy鈥� is being able to read and understand fundamental financial statements. 鈥淔inancial expert鈥� means a person who has one or more of the following: an understanding of generally accepted accounting principles and financial statements; experience in applying such principles; experience preparing or auditing financial statements; experience with internal controls; and an understanding of audit committee functions. At least one member of the committee should be familiar with compliance and ethics programs. The Chair of the Audit and Compliance Committee is the liaison between the University Board of Trustees and the Audit and Compliance Committee. The Chair should meet directly with the President, the Inspector General/Internal Auditor, and the Chief Compliance Officer to discuss investigative concerns and other matters, as needed, and be consulted by the President on the appointment, reassignment, replacement or dismissal of the Inspector General and the Chief Compliance Officer.
3. Meetings
The Committee shall meet at least three (3) times annually. Additional meetings may be held as the circumstances warrant. The meetings will be open to the public, with requisite notification. The Committee will invite members of management, auditors, compliance officers, or others to attend meetings and provide pertinent information. The Chair of the Committee should discuss the meeting agenda with the Inspector General/Internal Auditor or Chief Compliance Officer prior to each committee meeting to finalize the meeting agenda and review the issues to be discussed. Agendas and supporting documentation should be distributed in advance in order to improve meeting effectiveness and active member participation.
4. Responsibilities and Duties of the Committee
A. General
Management is responsible for the preparation, presentation and integrity of the University鈥檚 financial statements and for the appropriateness of the accounting principles and reporting policies used by 麻豆女郎. The following will be the responsibilities and duties of the Committee:
The primary purpose of the Audit and Compliance Committee is to assist the 麻豆女郎 (University) Board of Trustees in fulfilling its statutory, fiduciary and oversight responsibilities relating to:
- The integrity of the University鈥檚 financial accounting and reporting processes
- The maintenance of an effective system of internal controls
- The performance of the University鈥檚 independent audit and compliance functions
- The governance of the Compliance and Ethics Program
- Maximizing compliance with applicable laws, regulations, rules, policies, and procedures including the Code of Ethics and Conflict of Interest policies
- Monitoring and controlling risk exposure
- Maintaining open and direct lines of communication with the Board of Trustees, the administration, internal auditors, independent auditors, compliance officers, and internal compliance specialists
- Safeguarding University personnel and the physical, financial and information assets of the University
2. Composition
The Chair and members serving on the Audit and Compliance Committee are appointed and removed by the Chair of the University Board of Trustees. The members will be free from any financial, family or other material personal relationship that would impair his or her independence from management of the University. Each member of the Committee should be financially literate and, if possible, at least one member should be a financial expert. 鈥淔inancial literacy鈥� is being able to read and understand fundamental financial statements. 鈥淔inancial expert鈥� means a person who has one or more of the following: an understanding of generally accepted accounting principles and financial statements; experience in applying such principles; experience preparing or auditing financial statements; experience with internal controls; and an understanding of audit committee functions. At least one member of the committee should be familiar with compliance and ethics programs. The Chair of the Audit and Compliance Committee is the liaison between the University Board of Trustees and the Audit and Compliance Committee. The Chair should meet directly with the President, the Inspector General/Internal Auditor, and the Chief Compliance Officer to discuss investigative concerns and other matters, as needed, and be consulted by the President on the appointment, reassignment, replacement or dismissal of the Inspector General and the Chief Compliance Officer.
3. Meetings
The Committee shall meet at least three (3) times annually. Additional meetings may be held as the circumstances warrant. The meetings will be open to the public, with requisite notification. The Committee will invite members of management, auditors, compliance officers, or others to attend meetings and provide pertinent information. The Chair of the Committee should discuss the meeting agenda with the Inspector General/Internal Auditor or Chief Compliance Officer prior to each committee meeting to finalize the meeting agenda and review the issues to be discussed. Agendas and supporting documentation should be distributed in advance in order to improve meeting effectiveness and active member participation.
4. Responsibilities and Duties of the Committee
A. General
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- Adopt a formal written charter that specifies the scope, responsibilities, processes, and practices of the Committee. The charter should be reviewed every three (3) years, updated as necessary, approved by the Audit and Compliance Committee, and forwarded for approval by the University Board of Trustees.
- Maintain minutes and records of the meetings and activities.
- Conduct or authorize investigations into matters within the Committee鈥檚 scope of responsibilities.
- Report Committee actions to the Board with such recommendations that the Committee may deem appropriate.
- Perform other governance oversight as assigned by the Board.
Management is responsible for the preparation, presentation and integrity of the University鈥檚 financial statements and for the appropriateness of the accounting principles and reporting policies used by 麻豆女郎. The following will be the responsibilities and duties of the Committee:
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- Review significant accounting and reporting issues, including complex or unusual transactions and highly judgmental areas, recent professional and regulatory pronouncements, and understand their impact on the financial statements.
- Review annual audit reports of direct support and affiliated organizations and intercollegiate athletics.
- Consider the effectiveness of the University鈥檚 internal control system, including information technology security and controls.
- Understand the scope of internal and external auditors鈥� review or internal control over financial reporting, and obtain reports on significant findings and recommendations, together with management reports.聽
- Review external audits of the University and its direct support organizations.
- Contract with external auditors, compliance specialists or consultants for special audits or other services related to the University鈥檚 affairs and report the results of any special projects or reviews to the Board.
- Approve requests for contracted or special accounting, auditing or investigative services.
- Approve any outsourcing of the chief audit executive/inspector general鈥檚 entire audit or investigative function before any such request is forwarded to the Board of Trustees and the Board of Governors for approval.
- Obtain Board of Governors鈥� approval before outsourcing the chief audit executive鈥檚 entire audit or investigative function.
- Provide quarterly updates to the Board of Governors鈥� Audit and Compliance Committee, through the Office of Inspector General and Director of Compliance (OIGC), of any chief audit executive vacancy unfilled for six (6) months and describe efforts taken to fill such vacancy.
- Review and approve the Office of Inspector General鈥檚 charter and the annual internal audit plan (and any significant changes).
- Review the independence, qualifications, activities, performance, and structure of the internal audit function to address unresolved restrictions or barriers or scope or access limitations.
- Review all significant findings and recommendations noted by internal auditors or external auditors prior to submission to the Board of Governors and the State Auditor General.
- Request of the internal and external auditors, and others, knowledge of any significant investigatory or other matters acknowledged through established procedures.
- Meet, at least annually, with appropriate members of the University administration, the inspector general, and independent auditors to discuss and evaluate the scope and results of audits and the University鈥檚 accounting procedures and controls.
- Receive and review all outside audits of the University or University-related organizations.
- Review the effectiveness of the internal audit function, including compliance with the Institute of Internal Auditors鈥� International Standards for Professional Practice of Internal Auditing.
- Require the Inspector General to develop and maintain a quality assurance improvement program in accordance with professional audit standards and require that such program be assessed by an external entity at least once every five (5) years.
- Subject to the State鈥檚 Sunshine Law, meet separately with the Inspector General and/or the President to discuss any matters that the Committee or internal audit believes should be discussed privately.
- Require the Inspector General to report annually on the activities of the office.
- Support the Chief Audit Executive/Inspector General in carrying out the duties and responsibilities consistent with Board of Governors Regulation 4.002, State University System Chief Audit Executives.
- Review and approve the Office of the Chief Compliance Officer鈥檚 charter, which shall be reviewed every three (3) years for consistency with applicable Board of Governors and University regulations, professional standards, and best practices, and the annual compliance and ethics work plan (and any significant changes).
- Review the independence, qualifications, activities, and structure of the compliance and ethics function to address unresolved restrictions or barriers or scope or access limitations.
- Obtain Board of Governors鈥� approval before outsourcing the function of the chief compliance officer.
- Provide quarterly updates to the Board of Governors Audit and Compliance Committee, through the Office of Inspector General and Director of Compliance (OIGC), of any chief compliance officer vacancy unfilled for six (6) months and describe efforts taken to fill such vacancy.
- Ensure the Office of Chief Compliance Officer has sufficient independence to encourage ethical conduct and compliance with laws and regulations without management interference.
- Review significant findings and recommendations noted by the compliance officer prior to submission to the Boards of Governors.
- Request of the compliance officer, and others, knowledge of any significant investigatory or other matter acknowledged through established procedures.
- Review the effectiveness of the Compliance and Ethics Program in preventing or detecting noncompliance, unethical behavior, and criminal misconduct.
- Subject to the State鈥檚 Sunshine Law, meet separately with the Chief Compliance Officer and/or the President to discuss any matters that the Committee or the Chief Compliance Officer believes should be discussed privately.
- In consultation with the President, annually review the staffing levels to fulfill the plans and mission as well as the adequacy of compliance staff qualifications and training.
- Require the Chief Compliance Officer to report annually on the activities of the office.
- Support the Chief Compliance Officer in carrying out the duties and responsibilities consistent with Board of Governors Regulation 4.003, State University System Compliance and Ethics Programs.
The 麻豆女郎 Compliance and Ethics Program (CEP) is intended to assist the University in achieving its financial, operational and strategic goals (as set forth in 麻豆女郎鈥檚 Strategic Plan for the Race to Excellence, 2015-2025) while promoting an organizational culture that encourages compliance with all institutional policies as well as federal and state laws and regulations. The CEP creates a structural foundation to prevent and detect violations of law and assist the University in encouraging ethical conduct. Ultimately, an effective compliance program ensures that there are adequate controls in place to reduce regulatory risks throughout the University and provides to the University President and the BOT Audit and Compliance Committee reasonable assurance that core compliance management practices are in place across the University for all compliance risk areas.
The following principles are recognized as important elements for an effective compliance program:
Committee Responsibilities:
Adopted October 22, 2018
The following principles are recognized as important elements for an effective compliance program:
- Effective compliance oversight;
- Periodic risk assessments to identify compliance risks;
- Policies, procedures and standards to detect and prevent violations of law;
- Effective training so that employees know the rules that apply to them;
- Monitoring and auditing to confirm that employees are following the policies;
- Prompt investigation and appropriate action to prevent similar offenses;
- Enforcement of policies through well publicized disciplinary guidelines;
- Periodic evaluation of the effectiveness of the CEP.
Committee Responsibilities:
- Provide leadership and oversight in the implementation and continuous improvement of 麻豆女郎鈥檚 CEP and the implementation and enforcement of the responsibilities and elements set forth in Florida Board of Governor鈥檚 Regulation 4.003, State University System Compliance and Ethics Programs;
- Identify and assess current and emerging compliance risk areas that are relevant to the University鈥檚 mission and objective;
- Identify best compliance practices, program priorities, and recommend policies and procedures to effectuate necessary improvements;
- Identify significant cross-jurisdictional compliance gaps, including determinations of 鈥渞isk ownership,鈥� mitigation strategies, and resource implications;
- Develop and implement standards to assess compliance risks and objectives throughout the University. The standards will assist compliance risk owners in designing and maintaining programs for their respective compliance functions and will establish roles and responsibilities, track compliance implementation across risk areas, identify gaps and trends in compliance efforts and implementation of corrective action, and report progress to the President and the BOT Audit and Compliance Committee;
- Assist with development of training and education on the CEP and compliance risk.
- Sharing best practices across University compliance functions; and
- Coordinating with other relevant University committees and/or activities.
Adopted October 22, 2018