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Operations Manager Training 2018

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Jeneeta O'Connor

on 16 August 2018

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Transcript of Operations Manager Training 2018

Compliance Services
Elements of an Effective Compliance Program
1. Written policies and procedures
2. A designated compliance officer and a compliance committee
3. Effective training and education
4. Effective lines of communication
To enhance the RF's tone at the top, provide executive level ethics and governance leadership, and to create a focused and compliant business environment resulting in:
Enhanced Productivity through Integrity
Better Communications through Transparency
Improved Employee Engagement through Commitment

Operations Manager Orientation

Serving a Culture of Compliance

Joshua B. Toas, Vice President of Compliance & Chief Compliance Officer

5. Standards enforced through well-publicized disciplinary guidelines
6. Auditing and monitoring
7. Response to detected offenses and corrective action plans and
8. Ongoing risk assessment
Hierarchy of Compliance and Ethics
Compliance Oversight
Board of Directors
Delegation and Responsibility
Chief Compliance Officer
Resources and Authority
RF President
Hierarchy of Compliance and Ethics
The RF’s Board of Directors through the Audit Committee oversees the implementation and effectiveness of the RF’s Compliance and Ethics program

The RF President ensures that the appropriate staff and resources are dedicated towards an effective compliance program

The RF Chief Operating Officer provides administrative oversight of the RF’s Chief Compliance Officer (CCO)

The RF’s General Counsel, the VP of Internal Audit, and the CCO work together to maintain the RF’s control environment
7 Warning Signs of Ethical Collapse to Watch out for
1- Pressure to maintain numbers in a performance based system
2- Lack of communication and failure to openly discuss lapses
3-Young 'uns and larger-than-life CEO
4- Weak Board
6- Innovation like no other feeds ego and narcissism associated with success
7- Moral rationing
Policies Administration and Enforcement
Establishing Policies and Procedures Policy
General definitions and process
Policy review
Mandatory Review

Essential Policies and Concepts
Compliance Program
Code of Conduct
Signature Delegation
Conflicts of Interest Policy and Interest Disclosures
NYS Public Officer’s Law (POL)
Gift and Nepotism Policies
Travel and Entertainment Policies
Ethics Hotline
Fraud and Misconduct
Progressive Discipline Policy
Audit Standards Manual
Internal Control Methodology and Internal Controls
Record Retention and Destruction
Ethics Hotline
Duty to report potential fraud, misconduct, and violations of RF or SUNY policy
Procedure for Investigating Fraud and Misconduct
Non-retaliation and Confidentiality
Helps protect against fraud, waste, and abuse
Ethics Hotline:
or 800-670-7225
1. Written policies and procedures
2. A designated compliance officer and a compliance committee
3. Effective training and education
4. Effective lines of communication
The Office of Compliance Services
Joshua B. Toas
VP of Compliance, Chief Compliance Officer,
Assistant Secretary
Jeneeta C. O'Connor
Compliance Associate
Judy K. Burns
Risk Management Coordinator & Insurance Specialist
Alexis R. Phillips
Compliance Assistant
Nadia M. Sidarous
Senior Administrative Assistant

Campus Relationships
Campus Operations Managers
Enterprise Compliance Team
Campus compliance, risk, and audit professionals
Various functional stakeholder teams, i.e. SPMC
Why Compliance?
“Study after study confirms it: the vast majority of people act based on the circumstances in their environment and the standards set by their leaders and peers, even if it means compromising their personal moral ideals.
‘Good’ people do bad things if they are put in an environment that doesn’t value values, if pressured to believe that they don’t have any choice but to get the job done – whatever it takes.”

-The Importance of Ethical Culture: Increasing Trust and Driving Down Risks, The Ethics Resource Center
Corporate Ethics and Values-

Hotline Management – Internal Investigations

Risk Management and Internal Controls-

Corporate Records Management-

Policy and Procedure Administration, Guidance, and Development

Research and Sponsored Programs Compliance Support

OM Appointment
Compliance and You
Familiarize yourself with the Code of Conduct;
Work to prevent and detect any compliance violations;
Ensure compliance with federal, state, RF, campus and sponsor-specific policies and procedures;
Manage Conflicts of Interest;
Promote a healthy environment that allows people to raise concerns; and
Ensure that reports of violations on your campus are properly resolved.
Research Foundation board members, officers, and employees may not have any interest or engage in any outside activity which results in an unmanaged Conflict of Interest.
A conflict of interest arises if our personal relationships, activities, or finances interfere, or appear to interfere, with our ability to act in the best interests of the Research Foundation or creates an unwarranted personal gain.
A conflict exists whenever you are in a position to:
Disclose or use confidential material for personal gain or for the gain of your related party;
Intentionally and illegally use the property, funds, or other resources of the RF or SUNY for an unauthorized purpose; and/or
Give reasonable basis for the impression that your professional judgement is likely to be compromised.
5 Steps to Work Through a Conflicts Issue
Annual/Situational Disclosures

Nature and scope of the relationship, likelihood of harm or appearance of impropriety, risk appetite
Create an arms length arrangement & decide if the proposed activity is permissible
Ongoing obligation for due diligence and review
Maintain a copy of the disclosure, management plan & all related communications
Conflicts of Interest
Delegation of Authority
Code of Conduct-
Conflicts Management
What You Need to Know
Office of Compliance Services
Delegations of Authority Office of Record
Code of Conduct
Conflicts Management
Gift Guidance
Chair, Enterprise Compliance Team
Enterprise Compliance Team (ECT)

The ECT is a cross-functional campus and central office advisory body that supports the Office of Compliance Services (OCS) in carrying out its functions. The ECT will provide input and feedback to these functions of the OCS:

1) Policies
2) Enterprise Risk
3) Internal Controls
As an RF Operation’s Manager you are authorized to:
Act or authorize others to act in the name of the RF, commit RF resources and staff, obligate the RF to perform certain activities, and otherwise legally bind the RF.
Further delegate this authority to your colleagues and staff as needed to carry out day-to-day business.
Take actions consistent with the level of authority delegated to you and you may not further delegate authority in excess of the authority you possess.
As Operations Manager, you are responsible for ensuring that RF employees at your campus uphold the highest ethical standards, abide by the
RF's Code of Conduct
and other policies governing ethical behavior, including the
Conflict of Interest Policy
. As part of your orientation you will be asked to complete the
Annual Code of Conduct Acknowledgement and Certification
and the
Annual Conflicts of Interest Disclosure Form
Filing Schedule:
- Initial Annual Certification Notification
- Certification Status Report to Campus Human Resources Officers
- Certification Status Report to RF Board of Directors
Scheduled automatic reminders will continue for employees that have not completed their certification for the year.
All administrative Research Foundation Employees are
to read the Code of Conduct and complete the Code of Conduct Attestation
OMs and Deputy OMs will receive a notification to complete a "Code of Conduct Attestation" through the Osprey RiskManager System (Osprey)
All other employees must complete their certifications in Oracle.*

Annual Certification
What We Expect of Our Employees:

i. Act Ethically and with Integrity
ii. Be fair and respectful to others
iii. Manage responsibly
iv. Protect and preserve RF resources
v. Promote a culture of compliance
vi. Ethically carry out sponsored research
vii. Avoid conflicts of interest
viii. Carefully manage information
ix. Promote health and safety in the workplace
x. Follow the law

Filing Schedule:
Each Fiscal Year
- Annual Delegation of Authority Request
A conflict of interest must be managed so the conflict is reduced or eliminated, and compliance with conflict of interest management plans should be monitored where necessary.
Operations Managers must complete a Delegation of Authority Form for their campus to identify which key functional responsibilities are being delegated. This includes designation of a Deputy OM.
Learning and Development
Two training concerns:
General C & E for all employees and
Content Specific for appropriate employees
Key Training Components:
Code of Conduct and COI Policies
How to report concerns – Ethics Hotline
Vendors and RF Ethics
Duty report

Training plan by Department/Function
Functionally specific
The RF Ethics Program Part1 : Tone at the Top and the RF Code of Conduct 1-15-13
The RF Ethics Program (Part 2): Gifts to Employees from Non-RF Sources, Nepotism, Fraud and Whistleblower policies 1-29-13
Ethics Compliance 5-20-14
Remember to Watch:
Research Foundation for SUNY
-Research Foundation Code of Conduct
Fraud and Whistleblower Policy
has the following primary purposes:
Management is responsible for the detection and prevention of Fraud and Dishonest Conduct involving anyone representing or acting on behalf of the Research Foundation or those doing business with the Research Foundation.
Supervisors are
to report suspected Fraudulent or Dishonest Conduct.
Supervisors who become aware of suspected misconduct:
All credible allegations of Fraudulent or Dishonest Conduct will be reviewed and investigated.

The Office of Compliance Services has the
primary responsibility
for the coordination and documentation of an investigation of all suspected Fraudulent or Dishonest Conduct.

Campus Operations Managers may not conduct their own internal investigations.
Step 1- Initiate review of allegation received
To encourage all individuals doing work on behalf of the Research Foundation to raise or report good faith concerns regarding suspected or actual Fraudulent or Dishonest Conduct;
To facilitate cooperation in any inquiry or investigation;
To prohibit Retaliation against any employee making a Good Faith Disclosure or participating in good faith in a Research Foundation investigation under this policy;
To facilitate the development of controls aiding the detection and prevention of Fraudulent or Dishonest Conduct against the Research Foundation; and
To promote behavior consistent with the Research Foundation’s Code of Conduct.
Step 6- Submit a disclosure, board management report, or discipline as warranted.
Step 5- Issue and document final report
Step 4- Document the allegation and investigation
Step 3- Gather and review relevant facts and regulatory/policy guidance
Step 2- Identify Lead Investigator
Procedure for Investigating Fraud and Misconduct
Should not report the case to an authorized law enforcement officer without first discussing the case with Management
Should not discuss the case with outside attorneys, the media or anyone other than RF Counsel, Internal Audit, or the Office of Compliance Services.
Should not contact the person suspected to further investigate the matter or demand restitution
* Employees currently enrolled in Osprey must complete their Code of Conduct through that system, rather than in Oracle.
*Timely submission of delegation forms is required in order to proceed with Annual Conflict of Interest roll out
•Audit Committee
Joshua B. Toas,
Vice President of Compliance &
Chief Compliance Officer

Jeneeta C. O'Connor, JD, MBA, CCEP
Compliance Associate
Nadia M. Sidarous, CCEP
Senior Administrative Assistant
Alexis R. Phillips
Compliance Assistant
Judy K. Burns
Risk Management Coordinator & Insurance Specialist
The Office of Compliance Services offers additional trainings:
Corporate Ethics
Conflicts of Interest
Investigator Training
Ethics & Leadership
Ethics & Diversity
Compliance & Ethics Week
Animated trainings
Key Employees at the campus include (as designated by the OM’s delegation of authority):
• Vice presidents
• Operations managers
• Deputy operations managers
• Chief research officers when fulfilling RF obligations
• Technology transfer directors
• Sponsored program office directors or equivalent
• Other appointed officers

Annual filers (RF Board Members, Officers,
Operations Managers (OMs)
Deputy Operations Managers
, Key Employees) and RF Central Office Employees must electronically report all Direct or Indirect, Financial or Other Interests that pose, or may pose, a real, apparent, or potential Conflict of Interest through the RF Compliance Management System.
Operations Managers must select one of two options for filing disclosures at their campus:
1. Electronic Filing with Centralized Review
Annual filers will file a disclosure electronically to be reviewed by the RF’s Office of Compliance Services.
Potential conflicts will be managed with the assistance of the campus.
Non-annual filers will file a disclosure on paper, when necessary, to be reviewed by the OM or designee.
2. Electronic Filing with Local Review
Annual filers will file a disclosure electronically to be reviewed by the OM or designee.
Non-annual filers will file a disclosure on paper, when necesary, to be reviewed by the OM or designee.
Filing Schedule:
- Initial Annual Conflict of Interest Disclosure Request
Scheduled automatic reminders will continue for employees that have not submitted their disclosure for the year

*Filers are required to submit an updated disclosure if new potential conflicts arise throughout the year
Conflicts Management
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