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

-

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