Representative Observable Behaviors
- Reviews College Policy and Procedure for guidance in work matters.
- Follows direction per College Policy and Procedure.
- Reviews unit guidelines and protocols.
- Follows unit guidelines and protocols.
- Is compliant with the rules in settings with little to no oversight—does the right thing even when no one is watching.
- Seeks guidance from supervisor or other responsible person when uncertain.
- Completes required training.
- Recognizes a potential conflict of interest.
- Does not engage in activities or decisions that create a potential conflict of interest.
- Seeks guidance from supervisor or other responsible person when uncertain of whether a conflict of interest might exist.
- Identifies compliance-related requirements within his/her job.
- Meets compliance-related requirements of their job.
- 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.
- Maintains current knowledge of industry specific compliance requirements and shares the information with their supervisor and colleagues.
- Escalates potential compliance gaps.
- Reports concerns to direct supervisor, the College’s confidential reporting line (EthicsPointnew window), or other appropriate office.
- Does not begin to investigate or gather facts regarding suspected concern.
- Does not share the suspected concern with other employees.
- If suspected concern sustains overtime, checks back with the person or office to whom the concern was escalated.
- 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.
Warning Signs of Problematic Behavior
- Selectively references College policy and procedure when doing so is to their advantage, but rarely applies policy and procedure to their own conduct.
- Makes decisions without consulting policies or procedures.
- Uses College time inappropriately.
- Misuses College property or appropriates it for personal use.
- Fails to complete required training.
- Takes an action that gives rise to an actual or perceived conflict of interest.
- Misses a deadline driven by an oversight body.
- Disregards compliance requirements.
- Ignores wrongdoing.
- Fails to escalate wrongdoing when appropriate.
- 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.
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