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University of 91߹Compliance Charter

Introduction

The University of Nebraska's (the “University”) compliance program supports the University’s fundamental commitment to the highest standards of ethics, integrity, and lawful conduct by promoting adherence to all applicable federal, state, and local laws, and implementing regulations, as well as standards and internal policies, procedures, and protocols. The University has established a compliance program to ensure compliance activities are reasonably designed, implemented, and effective in preventing compliance violations and in fostering a culture that promotes compliance in all University programs, services, and activities.

Institutional compliance promotes greater coordination of and consistency among individual campus compliance programs, covering a wide variety of requirements related to academics, athletics, human resources, research, health care, information technology, and numerous administrative functions. The University’s compliance program shall seek to maximize efficiencies and promote best practices including, but not limited to, the development and sharing of system-wide subject matter expertise, training and education.

Professional Standards

The compliance program’s objective is to establish and promote standards that meet the U.S. Federal Sentencing Guidelines’ criteria for an effective compliance program:

  1. Compliance standards and procedures to prevent and detect criminal activity;
  2. Oversight by high-level personnel, with periodic reporting to the Board of Regents from individuals with operational responsibility;
  3. Due care in delegating substantial discretionary authority;
  4. Effective communication and training for all levels of employees;
  5. Systems for monitoring, auditing, and reporting suspected wrong-doing without fear of reprisal and
  6. for periodically evaluating the effectiveness of the compliance programs;
  7. Consistent enforcement of compliance standards including mechanisms to perform in accordance
  8. with the compliance program; and
  9. Reasonable steps to respond to and prevent further similar offenses upon detection of a violation.

Core Functions

The University compliance program’s core functions include, but are not limited to:

  • Providing strategic guidance, informing best practices, and identifying program priorities to assess and enhance the effectiveness and efficiency of university compliance processes and respond to changes in the law.
  • Leading the development and implementation of policies and procedures to ensure alignment with government laws and regulations across the University.
  • Identifying and assisting University system leadership in prioritizing and remediating institutional
  • compliance risks.
  • Developing, implementing, and managing effective compliance-related educational and training programs to ensure students, employees, and leadership are knowledgeable of institutional policies and pertinent state and federal standards.
  • In conjunction with University Internal Audit and Advisory Services, develop, implement and conduct a system for internally reviewing University processes, systems, and activities to ensure compliance with federal, state, and local regulatory requirements and University policies and procedures
  • Directing the assessment, management, and investigation of alleged and/or identified compliance issues and detected offenses arising through the University reporting hotlines or otherwise, and overseeing initiatives to prevent potential violations of rules, regulations, policies, and procedures.
  • Establishing collaborative efforts to build a structural foundation to prevent and detect violations of law and assist the University in encouraging ethical conduct.
  • Where necessary, recommend adequate controls to reduce regulatory risks throughout the University.
  • Providing University leadership with reasonable assurance that core compliance management practices are in place across the University for all compliance risk areas through a cadence of formal reports.

Roles and Organization

  1. 91߹ Audit, Risk and Compliance Committee: The purpose of the Audit, Risk and Compliance Committee is to provide advice and guidance to the Board of Regents regarding the oversight of (i) the integrity of the University’s financial statements, (ii) the University’s compliance with laws and regulations (iii) the independent auditors’ qualifications and independence, (iv) the performance of the University’s internal audit function, (v) the accounting and financial reporting processes of the University (vi) the University’s Risk Management process, including fraud risk management (vii) the code of conduct, (viii) the governance structure and, (ix) the internal control processes. The Audit, Risk and Compliance Committee shall obtain regular updates regarding compliance matters to include the results of any significant investigations.
  2. The President, Chancellors, and Senior Leadership: The President, Chancellors, and Senior Leadership support the compliance program and the performance of its core functions by: (i) promoting a culture of ethics and compliance throughout the University; (ii) directing the provision of appropriate resources within the program in collaboration with campus and system leadership; (iii) meeting regularly with compliance leadership to discuss risk, ethics, and compliance issues facing the University; and (iv) directing compliance concerns to the University System Chief Compliance Officer, campus compliance leadership, and/or other compliance personnel as appropriate.
  3. University System Chief Compliance Officer: The University System Chief Compliance Officer provides leadership and support of the University system compliance programs and initiatives by: (i) overseeing and/or assisting with performance of compliance program core functions and other related activities; (ii) meeting regularly and collaborating with campus compliance leadership, compliance personnel, and other University stakeholders in support of an efficient and effective compliance program; and (iii) providing periodic reports and updates as necessary to the Audit, Risk and Compliance Committee. The University System Chief Compliance Officer reports administratively to the Vice President for Business & Finance with a direct reporting authority to the President.
  4. Campus Compliance Leadership & Compliance Personnel: Campus Compliance Leadership and Compliance Personnel provide leadership and support of campus compliance program core functions and initiatives in support of the University’s fundamental commitment to the highest standards of ethics, integrity, and lawful conduct. Campus Compliance Leadership shall have direct access to their respective Chancellor and the University System Chief Compliance Officer for the purposes of reporting compliance issues and concerns, as necessary.
  5. The University Community: In accordance with Board of Regents Bylaw 1.10, Code of Ethics, the members of the Board and all University employees are expected to conduct themselves fairly, honestly, in good faith, and in accordance with the highest ethical and professional standards and to comply with applicable laws, regulations, and contractual obligations, and University policies.

Charter Review and Approval

The University System Chief Compliance Officer shall lead a review of this Charter, at minimum, every three (3) years. Proposed revisions shall be approved by the President and reported to the Board of Regents Audit, Risk and Compliance Committee.

Effective: November 07, 2019

Revised: February 22, 2021, February 6, 2025

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