A comprehensive institutional compliance program is one that integrates
and coordinates all significant requirements with which the institution
must comply by law, regulation or other binding rule or agreement. Comprehensive
organizational compliance programs are common in highly regulated industries,
and are increasingly present in higher education after the passage of
the Sarbanes-Oxley Act and some well-publicized cases of over-billing
of federal agencies.
Currently at Princeton, there are many different policy manuals, but the
overarching publication that speaks to principles of conduct for all
members of the University is "Rights, Rules, Responsibilities." These
principles are designed to protect the well-being of the University community
and to advance its educational mission by deterring wrongdoing and promoting
honest, ethical conduct.
Underlying these principles are many policies and procedures related
to specific issues. One objective of an institutional compliance
program is to inventory and consolidate operative principles and policies
so that all members of the community have easy access to general principles
and detailed policies and procedures.
An institutional compliance program based on Sarbanes-Oxley and the
Federal Sentencing Guidelines demonstrates that there is an
internal process to prevent and detect violations of law. Minimum
- Establish and communicate institutional principles designed to deter
wrongdoing and to promote honest and ethical conduct.
- Develop and effectively communicate policies and procedures.
- Designate an institutional compliance officer.
- Implement a program to monitor compliance and, when gaps or violations
occur, to develop responses to correct deficiencies in a timely manner.
- Ensure that the appropriate University department/governing body has
identified appropriate disciplinary sanctions and has applied those
sanctions when infractions occur.
Roles and Responsibilities for Compliance Initiatives
at Princeton University
- Audit Committee of Board of Trustees
Executive Compliance Committee
- Reviews the state of institutional
compliance at Princeton and plans to address compliance
Chief Compliance Officer
- Helps the compliance officer solicit compliance
ideas, determine priorities, review the annual compliance plan, review
proposed approaches to monitoring compliance, encourage institution-wide
cooperation and help ensure general follow-up to compliance reports.
The committee will provide general oversight and work to make sure
the importance of compliance is well publicized and well understood throughout
- Ensure that the cognizant University governing
entity takes appropriate disciplinary action when violations occur,
and in the absence of a governing body, determines appropriate actions
and ensures such actions are taken.
- Secures necessary funding from the provost to carry out the
- Develops institutional compliance program elements.
- Promotes compliance awareness through publicity and education
and training programs.
- Develops compliance monitoring program working with Internal
Audit and the Compliance Liaisons to ensure that all relevant
laws and regulations are being monitored and that appropriate policies
and processes have been established and communicated to applicable
members of the University community.
- Develops plans and priorities to ensure that compliance deficiencies are addressed in a timely manner.
- Implements and publicizes a "University Hotline" program.
- Identifies policy concerns that impede compliance. Ensures
cognizant office addresses deficiency in a timely manner.
- Networks with other university compliance officers throughout
the nation to keep apprised of emerging compliance issues,
share best practices, etc.
Faculty, Staff, Students and others who perform work at the request of the University
- Monitor applicable external laws and regulations
and ensure adherence to commitments made in binding agreements
with third parties.
- Develop and maintain institutional policies
and procedures to ensure that all University faculty, staff
and students operate in accordance with established rules.
- Provide training, manuals and information
to constituents so they understand how to comply with rules.
- Monitor compliance and initiate an action plan when deficiencies are identified.
- Understand and follow principles
of conduct in the comportment of their University obligations.
- Ensure that they and the staff who
report to them are aware of and operate in compliance with
applicable laws and policies.
- Report incidents of non-compliance or concerns.
Members of the Executive Compliance Committee
- Carolyn Ainslie, Vice President for Finance and Treasurer
- Pablo Debenedetti, Dean for Research
- Jay Dominick, Vice President for Information Technology, Chief Information Officer
- Robert Durkee, Vice President and Secretary
- Deborah Prentice, Dean of the Faculty
- Nilufer Shroff, Chief Audit and Compliance Officer
- A.J. Stewart Smith, Vice President for Princeton Plasma Physics Laboratory
- Lianne Sullivan-Crowley, Vice President for Human Resources
- Sankar Suryanarayan, Acting General Counsel
- Treby Williams, Executive Vice President, Chair of the Executive Compliance Committee
Princeton University would like to thank and extend its appreciation to
DePaul University, Stanford University, University of Minnesota and University
of Texas for their generosity and contributions to this Web site.
addition, a special thanks goes to the persons who have and will continue
to contribute their time and talents to this initiative.