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About the Ethics and Compliance Program

Standards of Conduct and Procedures

Standards of conduct set out in The Texas A&M University System (system) policies and regulations are designed to communicate to all system employees an expectation and requirement of ethical conduct and compliance with all applicable laws, policies, regulations, rules and procedures.

Standards of conduct provide guidelines for business decision-making and behavior. System policies and regulations in addition to Tarleton rules and procedures are the official standards for university operations. Policies and procedures provide the framework within which all employees are expected to operate and apply to all university employees.

Maintaining Tarleton rules and procedures that address changing university needs and regulatory requirements is an ongoing process. All areas of the university are involved in their development. The approval and review processes are coordinated by Risk Management and Compliance.

Oversight and Governance

The Campus Ethics, Compliance and Enterprise Risk Management Committee (CECEC) reports to the Executive Leadership Cabinet. The CECEC is composed of senior campus leadership representing the various areas of campus compliance risks and is chaired by the university's appointed institutional compliance officer. The charge of the CECEC is:

  • Facilitate coordination among various units of the university to identify and manage risks.
  • Query each institutional unit to identify risk items that pose a global threat to the university which can be categorized as operational, financial, reputational, strategic or compliance.
  • Develop and maintain an Ethics and Compliance Program that addresses the elements of an effective compliance program as detailed in the Federal Sentencing Guidelines.
  • Develop an annual Enterprise Risk Management (ERM) Report and annual Compliance Risk Plan to be presented to the Executive Cabinet for approval and submitted to the A&M System.
  • Develop a training plan and process to track training for existing and new employees.
  • Evaluate the effectiveness of current processes to identify and track risk items contained on the ERM and Compliance Risk matrices.
  • Publish an annual Risk Matrix on the ERM website and an annual Compliance Risk Plan on the Compliance website.

The CECEC will communicate instances of actual or suspected non-compliance to the institutional compliance officer as soon as possible after discovering or receiving possible violation report so that a review can be conducted and/or a corrective action plan implemented.

The CECEC meets quarterly to address risk mitigation, to provide appropriate resources for compliance and to ensure appropriate action for noncompliance issues brought to its attention. The institutional compliance officer submits a quarterly report to the Executive Leadership Cabinet and to the system Ethics and Compliance Office which provides updates on the annual work plan and compliance activities and processes.

Education and Communication

In order to "do the right thing," all Tarleton employees need a clear understanding of relevant compliance responsibilities and consequences for violations. A variety of strategies will be used for education and communication such as delivering training presentations and/or modules, posting a Tarleton Compliance Calendar, conducting campus surveys to assess the current knowledge of compliance issues. This list of strategies is not all-inclusive. Through the use of surveys and input from campus leadership, compliance education and communication can be targeted to meet specific needs.

Monitoring and Reporting

Employees are responsible for identifying and reporting risk and compliance concerns to management. Management is responsible for assessing compliance and safety risks, monitoring internal controls, reporting concerns, and taking corrective action as needed. The Ethics and Compliance Program supports management through internal reviews; assessments; monitoring of processes; compliance with system policies/regulations and university rules and procedures; and reviewing internal controls that facilitate compliance with internal reviews and assessments, monitoring of processes, and reviewing internal controls that facilitate compliance with internal and external regulations, policies, and rules. Reviews may be selected based on significant issues, risks, and other concerns identified by the CECEC, university leadership, and/or system, state and federal audits. Review findings, periodic reports, presentations and briefings apprise the Executive Cabinet of significant compliance risk areas and the status of program activities. University leadership supports all activities to expand awareness and facilitate responses to important compliance issues. In cases where noncompliance is found, corrective action plans are developed and communicated. Ultimately, the university leadership is responsible for compliance with all applicable laws, regulations, policies, and other directives.

Each member of the Tarleton community is expected to demonstrate workplace integrity and compliance with legal and regulatory requirements - "to do the right thing." This responsibility involves asking questions when there is uncertainty about the correct action for a particular situation, and reporting campus compliance risks and concerns.

The University Compliance Office website includes a mechanism where individuals may submit ethics and compliance questions and/or anonymously report compliance concerns. Also, the system-hosted Risk, Fraud and Misconduct Hotline is available to individuals to report wrongdoing anonymously without fear of retaliation.

Enforcement and Discipline

The responsibility for adhering to all laws, regulations, system policies and regulations and university rules and procedures rests on each member of the university community. Failure to comply with these may result in disciplinary action in accordance with system policies and regulations.

Response and Prevention

Response addresses the actions that are taken to ensure that compliance violations are remedied. Prevention addresses the steps that are taken to prevent similar compliance violations from occurring in the future.

The university will provide quick response to any compliance violation. When necessary, the institutional compliance officer will work with the appropriate university official(s) to ensure that an action/correction plan is in place to address the identified compliance violation and to prevent future violations. Depending on the level of the infraction, consultation with the system Office of General Counsel and/or the system ethics and compliance officer may be required.