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Final Version New Hire Orientation

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Jeneeta OConnor

on 16 August 2018

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Transcript of Final Version New Hire Orientation

Compliance Services
Elements of an Effective Compliance Program
To provide best-in-class compliance and ethics programming, training, and guidance in support of the Research Foundation’s mission to support the State University of New York.
1. Written policies and procedures
2. A designated compliance officer and a compliance committee
3. Effective training and education
4. Effective lines of communication
FOIL Appeals
Information Security and Privacy
Audit Support
Legal Support
Board Support & Corporate Governance

Sentencing Reform Act of 1984 created the field of corporate compliance
The Act created a series of “compliance” elements that could be used to mitigate a penalty resulting from a finding of liability or guilt
In 2003, Sarbanes-Oxley (“SOX”) focused attention on white collar crimes and strengthened the sentencing guidelines and mandated that those subject to SOX created an “effective compliance and ethics program.”
IRS standards, sponsor requirements, and New York laws incorporate elements of compliance.
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
The Research Foundation for SUNY's
Office of Compliance Services

Serving a Culture of Compliance
Employee Orientation

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

Enhanced Productivity
through Integrity
Better Communications through Transparency
Improved Employee Engagement
through Commitment
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:
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
•Audit Committee
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
You should be aware of the 7 Warning Signs that can lead to Ethical Collapse
1- Pressure to maintain numbers in a performance based system
2- Lack of communication and failure to openly discuss lapses
3-Young guns and larger than life CEO
4- Weak Board
6- Innovation like no other feeds ego and narcissism associated with success
7- Moral rationing
The Board and Compliance
The Board must ensure that management puts an effective compliance program in place and must understand who is responsible for what
Proper Board level understanding and communication can protect against corporate and INDIVIDUAL civil and criminal liability
It is essential for material compliance, audit, and legal concerns to be reported to the Board
Corporate Ethics and Values- what you need to know
NYS Public Officer’s Law
Code of Conduct
Conflicts of Interest Policies
Ethics Hotline
Fraud and Misconduct

Risk Management
You should assess the risk associated with:
Your work
New projects
Changing situations

Tools are available to help you evaluate and manage risk
Internal Controls
Internal Control Methodology
Internal Control Evaluation – stakeholders must review controls to mitigate current risks
Internal Control Testing and Monitoring – Self Assessment
Policies Administration and Enforcement
Establishing Policies and Procedures Policy
General definitions and process
Policy review
Mandatory Review

Essential Policies and Concepts for You
Code of Conduct
Conflicts of Interest Policy and Interest Disclosures
Fraud and Whistleblower Policy
Procedure for Investigating Fraud and Misconduct
Internal Control Methodology and Internal Controls
Progressive Discipline Policy
Record Retention and Destruction
Travel and Procurement Policies
Gift and Nepotism Policies
Public Officer’s Law (Section 74)
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
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
Joshua B. Toas, JD, CCEP,
Vice President of Compliance & Chief Compliance Officer

Alexis R. Phillips
Compliance Assistant
Nadia M. Sidarous, CCEP
Senior Administrative Assistant
Research Foundation
1. Written policies and procedures
2. A designated compliance officer and a compliance committee
3. Effective training and education
4. Effective lines of communication
Compliance Team

Joshua B. Toas
Chief Compliance Officer
Carol H. Berdar
Senior Research Compliance Manager
Jeneeta C. Howe
Compliance Associate
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. SPFG
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

Research and Sponsored Programs Compliance Support

What we do at Central Office
Compliance and You
Implement the Compliance Program
Code of Conduct
Conflicts Management
Gift guidance
High impact/investigation case management
Risk Management and Evaluation
Policy administration, guidance, development
Research compliance support
Delegations of Authority Office of Record
Chair, Enterprise Compliance Team
As an RF employee you should be:
Familiar with the Code of Conduct
Aware of what can go wrong
Follow the law and policies
Avoid conflicts
Understand the rules that govern your work
Discuss concerns as appropriate
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:
Jeneeta C. O'Connor, JD, MBA, CCEP
Compliance Associate
The Chief Compliance Officer should:
Assess risk,
Monitor controls,
Provide guidance on ethics and conflicts management,
Review training and education,
Administer written policies and procedures,
Investigate allegations of fraud or misconduct, and
Provide assistance in the enforcement of policy.
Full transcript