Compliance FAQ

What is Compliance?

Compliance means abiding by applicable laws, regulations, and policies. In a university setting, compliance is less about regulating individual behavior than it is about understanding applicable regulatory requirements that apply to university activities as an institution and ensuring that we meet them. Because Northwestern engages in such a broad range of activities, the number and scope of applicable requirements is vast. That makes understanding them and complying with them a challenging, university-wide endeavor.

Who is responsible for compliance?

Compliance at Northwestern is a job done by many people. Northwestern has a network of compliance experts on various topics who help to facilitate compliance with the range of obligations we face, legal experts to help interpret regulations and law, and managers who oversee compliance in the areas under their purview. But ultimately, compliance is the responsibility of every Northwestern community member – we are each responsible for making sure our Northwestern activities comply with any applicable regulatory requirements, policies, and standards.

What is the role of the Compliance Office?

The University Compliance Office helps to ensure that the University maintains the highest levels of integrity in its daily operations as it pursues its overall educational mission. The Compliance Office focuses on:

Serving as a resource to members of our community who need help reporting an issue or concern.
Helping members of our community understand whether something is allowed by policy.
Building awareness of compliance issues by disseminating information.
Educating managers about policies and procedures regarding compliance.
Monitoring compliance issues campus-wide, identifying risk areas, and assigning priorities.
Identifying and removing institutional barriers to compliance, such as policy gaps, lack of data or inadequate systems, lack of resources, organizational problems, or skewed incentives.
Providing institutional oversight and support to administrative operations in academic departments.
Providing oversight of University compliance programs, such as Youth on Campus and Clery Act compliance.

What are compliance issues?

Compliance issues can be related to activities, situations, and transactions that could potentially violate federal, state, or local laws and regulations, or violate Northwestern's policies, procedures, and rules. Examples include violations of regulations associated with research, conflicts of interest, environmental concerns, fraud, information security, fire safety, etc.

How do I know if there is a compliance or integrity issue?

Please use the guiding questions below to help you identify compliance or integrity issues. If the answer to any of these questions is NO, then there might be a compliance or integrity issue:

Are these actions legal?
Do these actions comply with university policy?
Do these actions seem fair and honest?

When in doubt, we encourage you to reach out with questions or to seek guidance. We are here to help.

If I think there is a compliance or integrity issue, what should I do first?

Speaking up can take courage. You have options if you think there may be a compliance or integrity issue. For example, you can:

Review policy. If you have observed potentially illegal or unethical behavior, you may wish to review related policies for guidance. While you do not need to investigate the issue yourself, it may be helpful to understand how policies may apply to the situation.
Discuss concern with your supervisor. Your supervisor or a department leader may be a good initial contact to discuss your concern and seek guidance on other appropriate steps.
Discuss concern with a compliance expert or University Compliance. Report your concern directly to a Compliance Expert or the University Compliance Office. Some concerns, like discrimination or sexual misconduct are required to be reported. If you are unsure where to report your concern, you can report to the University Compliance Office or through EthicsPoint, and we’ll get it to the right expert. You can also contact University Compliance Office at university.compliance@northwestern.edu
Submit a Report to the University's Hotline, EthicsPoint, either online or via phone (866-294-3545). EthicsPoint, a third-party system managed by University Compliance, is a way to report your concern to the university. EthicsPoint does not require a log-in, and allows people the option of identifying themselves or remaining anonymous. While remaining anonymous, reporters can correspond with University Compliance using the EthicsPoint system. Reporting issues – or potential issues – gives the university a chance to review the situation and take any necessary actions to intervene and correct behavior or processes.

What happens if I report a concern through EthicsPoint?

When a report is made through EthicsPoint, it is received by the University Compliance Office who review the report and determine whether the report falls under the purview / expertise of another office on campus - usually one of the subject matter experts in our Compliance Network. If so, we will refer the report to that office who will follow their own policies and processes to determine what, if any required next steps may be. If the report is complex, we may involve multiple subject matter experts to review and assess the report. When the report is referred elsewhere, the individual(s) who made the report will be notified of that action in the EthicsPoint portal.

If there is no dedicated office, University Compliance will complete an initial inquiry into the matter and conduct or facilitate any necessary investigation. When the reporting party is known, University Compliance will inform the individual(s) who made the report when review of the matter has concluded. The information that can be shared at the conclusion of the investigation may be limited.

In very rare cases, the issue may be escalated to University leadership and/or the Board of Trustees.

Note: If you need to make a report about someone within the University Compliance Office, the EthicsPoint system will not permit that member of the Office to view, or have knowledge of, the report.

Do I need to have evidence of misconduct to make a report in EthicsPoint?

No. Members of the community are encouraged to speak up and bring forward issues or concerns that they may have, regardless of whether they have specific evidence that there was misconduct. The ability to perform an investigation may depend on the availability of evidence and/or the willingness of an individual(s) making the report to identify themselves, but all concerns are reviewed.

In some instances, the outcome of such a report may be education, reminders of policy, or development of training on a specific topic.

If / when a member of the community has evidence of policy violations or misconduct, we ask that they provide it so that the matter can be appropriately addressed in accordance with university policies and procedures.

Can I report my concern anonymously?

Yes. EthicsPoint permits anonymous reporting in two ways:

You leave no contact information at all with your report. Upon submission, you will receive a key number to let you access your report and we encourage you to check back with the portal at regular intervals to pick up any messages posted there.
You provide your email address to EthicsPoint but remain anonymous to the university. This will permit EthicsPoint to notify you if follow-up questions or status updates are posted in the portal for your report. Northwestern will not see your email address if you choose this option.

EthicsPoint is a portal managed by a third party. When you leave a report, the University Compliance Office is notified of that report, and we log into the portal to review it. We can, and often do, post follow-up questions back to the reporter after reviewing the report to confirm understanding or request additional information that may be critical to reviewing a report.

Regardless of whether you remain completely anonymous, permit the system to send you notifications, or voluntarily provide your full contact information in your report, we strongly encourage you to respond to questions to the extent you are able.