University Compliance Program
Enhancing a culture of compliance and promoting ethical behavior
The University of Arizona Compliance Program reflects the commitment of the Arizona Board of Regents (ABOR) and the University of Arizona to conduct its educational, research, outreach, and health care activities in compliance with applicable laws and regulations, the ABOR Code of Conduct, university policies, and the highest standards of ethical conduct.
The policies, procedures, and standards referenced in this Program are designed to:
- Foster an institutional culture of ethics and compliance;
- Prevent noncompliance with applicable law and ethics standards;
- Detect noncompliance when it occurs;
- Respond appropriately to instances of noncompliance; and
- Reduce the likelihood of future noncompliance.
Leading by Example
The Role of University Leadership
The university president and senior leadership are committed to fostering a culture of integrity and ensuring that the university maintains an effective compliance and ethics program. They support the implementation and continuous improvement of the University's Compliance Program through appropriate oversight, resources, and accountability. The University Compliance Program is reviewed and updated periodically by University Compliance to address evolving legal and regulatory requirements and institutional priorities.
Centralized Compliance Coordination
The Role of the University Compliance Office
University Compliance provides oversight by authorizing, supporting, coordinating, and monitoring compliance activities across the university. Responsibility for implementing compliance requirements remains with the designated administrative units.
University Compliance:
- Oversees the implementation and continuous improvement of the Compliance Program;
- Provides the university president and senior leadership team with updates and recommendations regarding significant compliance matters;
- Oversees the Ethics & Compliance Hotline and the intake, assessment, tracking, and appropriate referral of reports of suspected misconduct or concerns to the responsible compliance personnel;
- Designates compliance personnel to perform compliance functions within their areas of responsibility, unless such authority is otherwise established by applicable federal, state, or local laws or regulations or by ABOR or university policy. Compliance functions may include providing guidance on compliance requirements; monitoring and assessing compliance; conducting investigations or compliance reviews; making determinations; and when noncompliance is identified, implementing or recommending corrective actions and measures to prevent recurrence.
A Collaborative, University-Wide Effort
University Compliance Advisory Committee
University Compliance partners with compliance personnel, university units, and relevant stakeholders to:
- Monitor and assess new laws, regulations, and trends that may affect the university’s compliance obligations;
- Develop compliance-related policies and procedures;
- Develop and deliver compliance-related education, training, and outreach programs and resources;
- Identify areas of potential noncompliance and facilitate necessary corrective action; and
- Evaluate and continuously improve the Compliance Program.
The Compliance Advisory Committee advises University Compliance and senior leadership on the effectiveness of the Compliance Program. Members are appointed by the Chief Compliance Officer in collaboration with senior leadership and include one or more representatives who have significant compliance responsibilities in the following areas of the university:
Support Through Partnership
University Compliance Partners
The university operates under a federated compliance model in which designated individuals, offices, and programs are responsible for implementing and managing compliance obligations within their assigned areas. The Compliance Program is implemented through a network of compliance professionals positioned across the institution to manage specific areas of compliance responsibility and risk. The heads of each university unit with compliance responsibilities:
- Act as the designated point of contact for the University Compliance Office;
- Support implementation of the university’s Compliance Program within their respective units; and
- Ensure that university employees, students, designated campus colleagues, and others within the scope of the unit's authority complete compliance training and related activities.
Compliance Personnel
Compliance personnel include, but are not limited to directors, managers, officers, designated institutional officials, and committee chairs with oversight of university compliance responsibilities.
For more specific information about designated compliance personnel, please see the full list of University Compliance Partners available on this site or contact University Compliance at complianceoffice@arizona.edu or (520)621-6436.
When compliance personnel identify noncompliance or recommend corrective action, the responsible university unit should promptly evaluate and address the recommendations. If compliance personnel determine that identified compliance risks have not been appropriately addressed or that recommended corrective actions have not been implemented, they should elevate the matter to an appropriate administrator within the unit's chain of command. Depending on the nature, significance, or urgency of the issue, compliance personnel may elevate the matter to a higher level of leadership. If the compliance concern remains unresolved, compliance personnel shall notify the Chief Compliance Officer for further review and appropriate action.
Compliance personnel are expected to cooperate with University Compliance by providing requested information, metrics, documentation, and assistance along with access to relevant internal and external compliance audits and reports.
Ensuring Consistency Through Effective Policy Creation
University Policies & Procedures
The university establishes and maintains policies that communicate its compliance obligations, ethical expectations, and operational requirements. These policies provide guidance to the university community and support compliance with applicable laws and regulations, ABOR policies, and university standards.
University policies address a broad range of institutional functions, including, but not limited to, the following:
- Academic Affairs & Faculty
- Administration, Business & Finance
- Employment & Human Resources
- Ethics & Conduct
- External Relations.
- Facilities
- Information Technology
- Privacy
- Research
- Safety
- Student Life & Education
These policies are available through the University's Policy website.
Supporting Adoption Through Learning
Education & Training
The university provides comprehensive education, training, and outreach programs to communicate compliance obligations, promote ethical conduct, foster a culture of integrity, and help prevent noncompliance. Compliance-related education is tailored, as appropriate, to the responsibilities of employees, students, and other members of the university community.
The university maintains information regarding the required trainings for all employees, as well as specific compliance-related training, and other resources to support compliance.
It Takes All of Us
Reporting Compliance & Ethics Violations or Misconduct
Members of the university community are expected to promptly report, in good faith, actual or suspected violations of laws, regulations, government contract or grant requirements, ethical or professional standards, or other suspected misconduct or noncompliance of which they become aware. Individuals can make direct reports to compliance personnel who are responsible for the applicable subject matter. The names of compliance personnel with responsibilities for particular areas are available on the University Compliance Partners webpage.
University employees may also report concerns through their normal management channels, beginning with their immediate supervisor. If reporting to an immediate supervisor is not appropriate, for example, because the supervisor is involved in the alleged misconduct, the concern may be reported to a higher level of management within the unit, to University Compliance at (520) 621-4192 or complianceoffice@arizona.edu, or through one of the university's confidential reporting channels.
Protecting Confidentiality & Preventing Retaliation
Confidential Reporting Channels
In the event that the reporting options outlined above are not appropriate or feasible, or if the reporter fears retaliation or reprisal and desires confidentiality, the reporter may use a confidential channel, which include:
- Certain Compliance Personnel. Direct reports to certain compliance personnel, if, by virtue of university policy, law, or regulation, they are charged with maintaining confidentiality. Reporters should confirm the scope of such confidentiality where appropriate.
- University's Ethics & Compliance Hotline, The Ethics & Compliance Hotline, (866)364-1908, is managed by an external vendor with reports sent to the University Compliance Office. Reports to the hotline are anonymous unless the reporter chooses to leave contact information. Reports must be made in good faith and not be frivolous in nature.
Response to Reports
University Compliance and compliance personnel will assess reports they receive of suspected violations of laws, regulations, or policy and investigate, if appropriate. Because reports often involve confidential, sensitive, or personnel-related information, the university may be unable to disclose the outcome of a review or investigation to the reporting individual.
The University of Arizona Prohibits Retaliation
The university prohibits retaliation against reporters of suspected noncompliance or misconduct, those who provide information, or those who cooperate or assist with an investigation. Individuals who believe they have experienced retaliation are encouraged to report their concerns using the reporting channels described above.
Addressing Suspected Noncompliance
Review & Resolution
University Compliance and designated compliance personnel will review and assess reports received of suspected misconduct or noncompliance, as appropriate. University Compliance may refer reports it receives to the appropriate compliance personnel who have responsibility related to the subject matters of the reports. When University Compliance refers a report to compliance personnel for review, those personnel will follow the investigatory procedures established by their compliance units, if applicable. When University Compliance refers reports to compliance personnel whose units do not have established investigative procedures, those units will follow protocols provided by University Compliance. University community members must cooperate fully with any such reviews.
Procedures Following Noncompliance
If University Compliance or compliance personnel determine, after review, that noncompliance has occurred, the matter will be addressed through appropriate corrective measures. As appropriate, the university may evaluate the underlying or root cause of the noncompliance to identify opportunities for corrective action or enhancements to policies, procedures, internal controls, training, or oversight that may reduce the likelihood of recurrence.
For employees, the relevant supervisor or unit leadership will address the matter in consultation with compliance personnel and/or University Compliance, as appropriate. Corrective or disciplinary actions will be determined on a case-by-case basis, and may include:
- Disciplinary action up to and including termination of employment or separation from the university;
- Referral to the appropriate authorities or government agencies; and
- Other corrective, remedial, or legal action as warranted.
All disciplinary matters will be conducted in accordance with university policies and procedures.