Post on 30-Dec-2015
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Anna Drummond, UMV Chief Compliance Officer
Robert F. Roach, NYU Chief Compliance Officer
2B. How’s Your Compliance Communication Service?
How’s Your Compliance Communication Service? Dropped Calls? Dead Zones? Quick Tips on
How to Provide Your Campus with a 4-Bar Communication Network
Anna Drummond
UVM Chief Compliance Officer
Robert F. Roach
NYU Chief Compliance Officer
Diane DelaneyNYU Compliance Manager
Importance of Compliance CommunicationsIntroduction and Guiding Principles
• Federal Sentencing Guidelines: each element of the FSG requires effective and continuous communications.
• Decision Making: In Universities, distributed responsibilities and collaborative decision-making demand open lines of communication.
• Ongoing Process: compliance is not an accomplishment; it is an ongoing process that requires effective communication in order to be responsive to changes in programming and the risk environment.
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Creating a Communications Plan: Elements of a Compliance Communications Plan
• Message
• Targeted Audience(s)
• Strategy and Tactics
• See UVM Communications Plan (CD Rom)
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What Is Your Message? Consider Primary and Secondary Messages
• Primary: the University is a community vested in modeling the highest standard of ethical conduct, accountability and best practices and compliance fosters these goals.
• Secondary: will contain more complex ideas, such as specific legal and regulatory mandates, University policies and protocols and their connection of the foregoing to the mission and vision of the University
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Target Your AudienceUniversity Communities are Diverse
University communities are diverse.
You must design your communications to address their varied background, education, awareness of compliance issues, time constraints, and attitudes toward compliance.
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Develop Strategies and TacticsPractical Examples
• Code of Ethical Conduct/Compliance Manual• Policies and Procedures • Orientation and Training• Response to Individual Concerns and Requests for
Advice• Surveys and Evaluations• Ongoing Communications
– Web based– Periodic Direct Communications– Outreach– Brochures and Guides, Posters, Promotional Items
• Collaborative Decision Making and Effective Oversight7
STRATEGIES AND TACTICS
Examples and Open Discussion
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Code of ConductThe Core of Compliance Communication
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Compliance Manuals
Code of Conduct/Policies/
Q and A/Sources of Info
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Policies and ProceduresPolicy on Policies,
Policy Websites
Policy Guides
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Policies and Procedures
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NYU.edu Home Page
See http://www.acupa.org/resources.html
Orientation and Training
• Ongoing training: regarding the code of conduct, compliance policies and process and relevant legal and regulatory issues should be developed and offered through a variety of methods, including live and web-based trainings.
Code of Conduct
Compliance Process
Legal and Regulatory Issues
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Response to Individual Concerns and Requests for Advice
Telephone and Web Based “Hotlines”
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Surveys and Evaluations
• Survey and Evaluations: can be helpful to establish a baseline for awareness of Compliance, the Code of Conduct and the Help Line. This can be achieved through use of a survey tool and direct calling. Similarly, a survey can be conducted after the roll out of each element of the Communications plan as an evaluation tool to determine whether the social awareness campaign has had any impact.
• Metrics and Evaluations: Other benchmarks of compliance communication and awareness can include the number of calls to the Help Line, the number of calls for guidance or inquiries, the number of visits to the websites (included websites: Policy website, Help Line, Compliance, and the President, Staff and Provost web sites where letters/articles are planted regarding Compliance), and referrals to Compliance from within the University.
See UVM Survey Handout
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Number of NYU Policies/Guidelines/Compliance Page Views
15,519
17,515
20,75622,067
20,369
14,372
11,871
25,534
23,608
14,20613,905
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5,000
10,000
15,000
20,000
25,000
30,000
# of Page Views
Newsletter Published
3 1 1 1 3 2 2 1 2 2 2 0
84
120
169158
233
217209
236245
351
0
289
0
50
100
150
200
250
300
350
400
Compliance Reporting Line Statistics for AY 2010-2011
# of Phone Calls
# of Page Views
250 PostersDistributed
Newsletter Published
Ongoing Communications
– Web based
– Periodic Direct Communications
– Outreach
– Brochures and Guides, Posters, and Promotional Items
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Web Based Communications
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Periodic Direct Communications
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Outreach
• Partnerships are important to the successful completion of the project. This will mean seeking invitations to work with groups and associations on campus. These groups provide a venue for awareness building through live interaction as well as for establishing training and materials distribution.
• Individual meetings with “influencers” within these groups and outside of them will also be sought. For example, principal investigators with control over students, labs, staff resources, etc., or who have influence with other researchers can be useful advocates.
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Posters
NYU Compliance Line Poster
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Tear-0ff Info Tear-0ff Info SheetSheet
Promotional Items
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The End!
Additional Questions and Comments