Mission & Strategic Plan

 

Texas Tech University Institutional Compliance and Ethics Statement

Texas Tech University (TTU) is committed to maintaining a culture that ensures ethical decisions and conduct among university administrators, faculty, staff, and students by providing a clear expectation that doing the right thing is a fundamental element of how we do business within the institution and with external constituents.

Ethical behavior and compliance with state and federal laws are integral to how the Texas Tech System and TTU operate. How faculty, staff, and students are expected to conduct themselves is outlined in the following policies:

• Texas Tech University System Regulation 01.05 - Ethical Conduct and Required Training

• OP 10.11: Ethics Policy

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United States Sentencing Commission Compliance Guidelines

The federal government requires that organizations, including higher education institutions, have compliance and ethics programs to prevent criminal conduct. The United States Sentencing Commission (the Commission) is an independent agency in the judicial branch of government created by the Sentencing Reform Act (SRA) of 1984. Congress enacted the SRA in response to widespread disparity in federal sentencing, ushering in a new era of federal sentencing through the creation of the Commission and the promulgation of federal sentencing guidelines.¹ Section 8B2.1. of the USSC chapter on organizational guidelines provides requirements for an effective compliance and ethics program to include the following²:

• Exercise due diligence to prevent and detect criminal conduct.
• Promote an organizational culture that encourages ethical conduct and a commitment to compliance with the law, which minimally requires the following:
  • Establish standards and procedures to prevent and detect criminal conduct.
  • Ensure the institutional governing authority (CEO) is knowledgeable about the content and operation of the compliance and ethics program and exercises reasonable oversight with respect to the implementation and effectiveness of the compliance and ethics program.
  • Delegate and support the compliance office’s day-to-day operational responsibility for the compliance and ethics program.
• The Office of Institutional Compliance (OIC) shall periodically communicate its standards and procedures, and other aspects of the compliance and ethics program, to members of the governing authority, high-level personnel, all other campus members by providing effective training programs and otherwise disseminating information appropriate to such individuals' respective roles and responsibilities.
• OIC shall —
  • ensure the compliance and ethics program is followed, including monitoring and auditing to detect criminal conduct;
  • evaluate periodically the effectiveness of the compliance and ethics program; and
  • have and publicize a system, which may include mechanisms that allow for anonymity or confidentiality, whereby employees and agents may report or seek guidance regarding potential or actual criminal conduct without fear of retaliation.
• The organization's compliance and ethics program shall be promoted and enforced consistently.
• If misconduct has been detected, the organization shall take reasonable steps to respond appropriately and to prevent further similar conduct, including making any necessary modifications to the organization's compliance and ethics program.
• The organization shall periodically assess the risk of misconduct and shall take appropriate steps to design, implement, or modify each requirement to reduce the risk of such conduct identified through this process.

OIC, under the governance of the CEO, monitors, educates, and advises the university community about TTU’s obligations under federal, state, and local laws and regulations. University policies and procedures are consistently reviewed for updates and are designed to foster a culture of compliance and ethical behavior. OIC conducts ongoing assessments of compliance performance across campus, to identify, eliminate, manage, and/or mitigate any identified compliance gaps.

TTU has a decentralized compliance oversight system where OIC directly oversees Title IX, Clery Act, Minors on Campus program, Privacy program (HIPAA), and Conflict of Interest as described in OP 10.20. Other areas such as research compliance, student privacy, athletics compliance, emergency management, fiscal compliance, safety compliance, facilities compliance, and procurement are overseen within other departments. These departments are listed here . OIC nonetheless partners with these departments and is apprised of issues that may arise within these areas. In addition, representatives from these departments are members of the compliance committee and relevant compliance updates and

The responsibilities and goals of the OIC include the following:

• Identify, assess, and define TTU’s risk profile and ensure appropriate measures are in place to avoid and/or mitigate those risks.
• Tailor a risk assessment that concentrates on high-risk areas, ensuring appropriate metrics are in place to help detect types of misconduct and reviewing and updating policies and training where gaps are identified.
• Develop compliance training with in-person and on-line options. Trainings will be consistently updated to include case studies and examples of misconduct found through investigations and will be measured through participation numbers and post-training surveys.
• Aside from EthicsPoint for anonymous reports monitored by the TTU System, OIC will be a point of contact for anyone wanting to report a claim of misconduct. OIC will partner with Human Resources and/or System Office of Audit Services to investigate and determine the appropriate recommendation for corrective action when misconduct is discovered.
• Monitor departments across campus to ensure they are encouraging compliance and mitigating risks within the campus community as well as with third parties.
• Through continual assessment of risks and when misconduct is found, OIC will recommend appropriate controls to manage those risks.

Through feedback and input from the Compliance Committee, as well as trainings and surveys, OIC will continuously review policies and practices to improve and mitigate additional areas of risk based on changes within the institution.

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¹https://www.ussc.gov/about-page

²https://www.ussc.gov/guidelines/organizational-guidelines