2B. How’s Your Compliance
Communication Service?
Anna Drummond, UMV Chief Compliance Officer
Robert F. Roach, NYU Chief Compliance Officer
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
Importance of Compliance Communications
Introduction and Guiding Principles
• Federal Sentencing Guidelines: each
element of the FSG requires effective and
continuous communications.
• Decision Making: In Universities, distributed
responsibilities and collaborative decisionmaking 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.
3
Creating a Communications Plan:
Elements of a Compliance Communications Plan
• Message
• Targeted Audience(s)
• Strategy and Tactics
• See UVM Communications Plan (CD Rom)
4
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
5
Target Your Audience
University 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.
6
Develop Strategies and Tactics
Practical 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 Oversight
7
STRATEGIES AND TACTICS
Examples and Open Discussion
8
Code of Conduct
The Core of Compliance Communication
9
Compliance
Manuals
Code of
Conduct/Policies/
Q and A/Sources of
Info
10
Policies and Procedures
Policy on Policies,
Policy Websites
Policy Guides
11
NYU.edu Home Page
Policies and Procedures
12
See http://www.acupa.org/resources.html
Orientation and Training
Code of Conduct
Compliance Process
Legal and Regulatory Issues
• 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 webbased trainings.
13
Response to Individual
Concerns and Requests
for Advice
Telephone and Web Based “Hotlines”
14
Surveys and Evaluations
See UVM Survey Handout
• 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
15 University.
Number of NYU Policies/Guidelines/Compliance Page Views
30,000
Newsletter Published
25,534
25,000
23,608
22,067
20,756
20,369
20,000
17,515
15,519
14,206
13,905
15,000
14,372
# of Page Views
11,871
10,000
5,000
/1
9/
11
-6
6/
13
/1
1
-6
/1
2/
11
6/
6/
11
/5
/1
1
-6
5/
30
/1
1
/2
9/
11
5/
23
/1
1
-5
/2
2/
11
-5
5/
16
/1
1
-5
/1
5/
11
5/
9/
11
-5
/8
/1
1
5/
2/
11
/1
/1
1
-5
4/
25
/1
1
/2
4/
11
4/
18
/1
1
-4
/1
7/
11
-4
4/
11
/1
1
4/
4/
11
-4
/1
0/
11
-
Compliance Reporting Line Statistics for AY 2010-2011
400
351
350
289
300
236
245
233
250
Newsletter
Published
209
217
250 Posters
Distributed
200
# of Phone Calls
# of Page Views
169
158
150
120
84
100
50
0
3
0
1
1
1
3
2
2
1
2
2
2
0
Ongoing Communications
– Web based
– Periodic Direct Communications
– Outreach
– Brochures and Guides, Posters,
and Promotional Items
18
Web Based
Communications
19
Periodic Direct
Communications
20
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.
21
22
Posters
NYU Compliance
Line Poster
Tear-0ff Info
Sheet
23
Promotional
Items
24
The End!
Additional Questions and
Comments