COMPLIANCE CHARTER
GARY NIMAX
AS S I S TAN T V I C E P R E S I D E N T F O R C O M P L I AN C E
U.S. Federal Sentencing Guidelines
The compliance program’s objective is to establish and promote
standards that meet these seven elements of an effective
compliance program:
Standards and procedures to prevent/detect criminal activity
Oversight by high-level personnel, with reports to the board
Due care in delegating substantial discretionary authority
Effective communication and training
Systems for monitoring, auditing and reporting suspected
wrong-doing without fear of reprisal
• Consistent enforcement of compliance standards
• Reasonable steps to respond to and prevent offenses
•
•
•
•
•
2
3
Compliance Charter
• Summarizes the mission of the compliance function
for the University, including its Medical Center, and
how the seven elements of an effective compliance
program are met
• Incorporates best practices by using elements of
compliance charters from other universities
• Specifies the professional standards and
responsibilities related to the compliance program,
and the interaction between the compliance, audit,
and ERM functions
4