Anna Drummond, UMV Chief Compliance Officer Robert F. Roach, NYU Chief Compliance Officer 2B. How’s Your Compliance Communication Service?

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 Diane Delaney NYU Compliance Manager

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 decision- making 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

Policies and Procedures 12 NYU.edu Home Page See

Orientation and Training 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 web- based trainings. Code of Conduct Compliance Process Legal and Regulatory Issues 13

Response to Individual Concerns and Requests for Advice Telephone and Web Based “Hotlines” 14

Surveys and Evaluations 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 University. See UVM Survey Handout 15

Newsletter Published

250 Posters Distributed Newsletter Published

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

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Posters NYU Compliance Line Poster 23 Tear-0ff Info Sheet

Promotional Items 24

The End! Additional Questions and Comments