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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.  Teams of compliance topic experts and legal experts help to facilitate compliance with the range of obligations we face, and managers 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.

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 the university community. Questions about who to call about an issue or whether something is permitted by policy?  We can help.
  • Building awareness of compliance issues by disseminating information.
  • Educating managers about policies and procedures regarding compliance.
  • Providing academic chairs or directors and their managers with “best practices” in terms of defining appropriate internal controls, developing customized reports for financial planning and reviewing the administrative organizational structure to assure departmental programs and research initiatives are well supported.
  • 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.

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 is probably a compliance or integrity issue:
  • Are these actions legal?
  • Do these actions comply with university policy?
  • Do these actions seem fair and honest?

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

  1. Identify Concern. If you have observed potentially illegal or unethical behavior, you may first wish to review related policies for guidance.
  2. Discuss Concern with Supervisor. Contact your supervisor for guidance about your concern.  If you are uncomfortable with this approach, see Step 3.
  3. Discuss Concern with HR or Compliance. Report your concern directly to the Office of Human Resources or the University Compliance Office.  If you are still uncomfortable, wish to remain anonymous, or have not received an adequate response, see Step 4.
  4. Submit a Report to the University's Hotline, EthicsPoint, either online or via phone (866-294-3545). EthicsPoint is managed by a third-party, does not require a log-in, and allows people the option of identifying themselves or remaining anonymous.

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 our key compliance partners.  If so, we will refer the report to that office who will follow their own policies and processes to determine what any required next steps are.  If the report is complex, we may involve multiple units 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, the report will stay with University Compliance, and we will conduct any investigation as needed, and let the individual(s) who made the report know when review of the matter has concluded.

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.