University Ethics and Compliance Plan

A. Introduction

The University of North Carolina at Charlotte Ethics and Compliance Plan (“Plan”) reflects the University’s overall mission and values, its commitment to the highest standards of ethics and its expectation that members of the University community comply with all applicable laws, rules and policies. The purpose of the Plan is to facilitate collaboration, inspire and promote a culture of accountability, integrity and trust, provide education and guidance, and to detect and prevent violations of our legal obligations or university policy.

The Plan provides oversight and guidance within a decentralized model. Certain functional areas within the University maintain local compliance programs under the direction of responsible individuals that are designed to achieve compliance with specific subject matter. The Director of University Compliance is responsible for the oversight of all University compliance activities and reports to the Vice Chancellor and General Counsel and the Audit, Compliance and Enterprise Risk Management Committee of the University Board of Trustees.

B. Standards of Ethical Standards

The University has set forth its commitment to ethical, legal, and professional behavior in all dealings both inside and outside the University in University Policy 804 – Standards of Ethical Conduct. This policy is applicable to all members of the University community. (Link to Policy)

C. Compliance Plan Elements

1. Compliance Official and Executive University Compliance Committee
   
   The Director of University Compliance is the designated University compliance official with oversight responsibility for the Plan and with the authority to report matters directly to the Chancellor and/or the Board of Trustees of the University. The Executive University Compliance Council is responsible for advising the Director and supporting the Plan. The Council will make recommendations regarding the strategic design and implementation of the Plan, receive periodic reports from the Director on compliance audit, education and awareness activities, recommend the allocation of resources to meet the University’s compliance obligations as necessary, and promote the University’s commitment to a culture in which its affairs are conducted with the highest standards of integrity and compliance.
2. Effective Communications
   
   The creation and maintenance of effective lines of communication between the compliance officer and all faculty and staff, to include mechanisms to report ethics and compliance issues anonymously.
3. Auditing and Monitoring
   
   The use of regular audits and/or other risk evaluation techniques to monitor compliance and identify areas compliance risk exposure.
4. Education and Training
   
   The Office of University Compliance will coordinate ethics and compliance education for members of the Board of Trustees, faculty and staff. Subject-matter specific education will be also be provided to members of the University community in areas where there is potential risk exposure.
5. Disciplinary Actions
   
   The enforcement of appropriate disciplinary action against students, employees, and volunteers who engage in behavior contrary to University Policy 803, Standards of Ethical Conduct, or behavior that is not in compliance with existing federal, state, local, and University laws, regulations, and policies.
6. Investigative Process and Corrective Actions
   
   The maintenance of a process for responding to and investigating reports of suspected non-compliance, resolving and effecting appropriate corrective, restorative and/or disciplinary actions.
7. Periodic Risk Assessments
   
   The development and maintenance of a compliance risk assessment process that identifies and evaluates material compliance risks to the University and a compliance risk management process that manages or eliminates risks to the University.
8. Revisions to the Plan
   
   This Plan is intended to be flexible and readily adaptable to changes in regulatory requirements. The Plan will be reviewed periodically to assess whether it is providing the desired results. The Director of University Compliance has the authority to amend this Plan as deemed necessary.