Compliance

1. Reviews College Policy and Procedure for guidance in work matters.
2. Follows direction per College Policy and Procedure.
3. Reviews unit guidelines and protocols.
4. Follows unit guidelines and protocols.
5. Is compliant with the rules in settings with little to no oversight—does the right thing even when no one is watching.
6. Seeks guidance from supervisor or other responsible person when uncertain.
7. Completes required training.

1. Recognizes a potential conflict of interest.
2. Does not engage in activities or decisions that create a potential conflict of interest.
3. Seeks guidance from supervisor or other responsible person when uncertain of whether a conflict of interest might exist.

1. Identifies compliance-related requirements within his/her job.
2. Meets compliance-related requirements of their job.
3. Provides prompt and advance notice to direct supervisor if there is the potential that a compliance requirement (within that employee’s job responsibilities) is behind schedule or unlikely to be met.
4. Maintains current knowledge of industry specific compliance requirements and shares the information with their supervisor and colleagues.
5. Escalates potential compliance gaps.

1. Reports concerns to direct supervisor, the College’s confidential reporting line (EthicsPointnew window), or other appropriate office.
2. Does not begin to investigate or gather facts regarding suspected concern.
3. Does not share the suspected concern with other employees.
4. If suspected concern sustains overtime, checks back with the person or office to whom the concern was escalated.
5. When a colleague shares a suspected incident of wrongdoing, provides guidance for them to appropriately escalate the concern. Does not communicate the concern to other employees.

1. Selectively references College policy and procedure when doing so is to their advantage, but rarely applies policy and procedure to their own conduct.
2. Makes decisions without consulting policies or procedures.
3. Uses College time inappropriately.
4. Misuses College property or appropriates it for personal use.
5. Fails to complete required training.
6. Takes an action that gives rise to an actual or perceived conflict of interest.

1. Misses a deadline driven by an oversight body.
2. Disregards compliance requirements.

1. Ignores wrongdoing.
2. Fails to escalate wrongdoing when appropriate.
3. Interferes with or dissuades colleagues from bringing forward suspected wrongdoing.

U.S. Department of Justice Criminal Division
Evaluation of Corporate Compliance Programs Guidance Documentnew window (2019)

Building a World-Class Compliance Program : Best Practices and Strategies for Successnew window. Biegelman, Martin T., and Daniel R. Biegelman. Hoboken, N.J.: John Wiley & Sons, 2008.

• Bridges: Building a Supportive Community
• Child Abuse and Molestation Awareness and Prevention in Maryland
• Ethics@MC: Code of Ethics and Employee Code of Conduct

• Ethics and Compliance Initiativenew window
• Higher Education Compliance Alliancenew window
• Montgomery College Office of Compliance, Risk, and Ethics Webpagesnew window
• Society for Corporate Compliance and Ethicsnew window