Norlin Charge: The university is not the campus, not the buildings on the campus, not the faculties, not the students of any one time — not one of these or all of them. The university consists of all who come into and go forth from her halls, who are touched by her influence and who carry on her spirit. Wherever you go, the university goes with you. Wherever you are at work, there is the university at work. - University of Colorado Boulder President George Norlin

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At the University of Colorado Boulder, our vision is to be a leader in addressing the humanitarian, social and technological challenges of the twenty-first century. Underpinning this vision is our commitment to the highest ethical standards in all that we do. Inspired by our students’ Colorado Creed, we commit to act with integrity, courage, and respect. These values are reinforced by our Inclusive Excellence Initiative and our identity is defined by respect for diversity and inclusivity.  To that end, we restate our values as follows:

Collaboration: foster partnerships across the campus community, value diverse perspectives, interdisciplinary/transdisciplinary work, and work with all campus constituents to remove barriers and solve problems
Communication: Ensuring that key critical information is shared in a timely fashion. Developing and delivering information in multi modes that demonstrate the needs of different audiences.
Inclusive Excellence: Exemplifying excellence through diversity by creating a welcoming and inclusive environment, deepening our ability to share and to engage with diverse perspectives that maximizes the success and inclusion of all students, staff, and faculty.
Innovation: Creating new and better ways for the organization to be successful. Adapting to change and engaging in continuous learning and critical thinking to promote the growth of the individual and the organization.
Integrity, Responsibility, Ethics: Gaining the confidence and trust of others through honesty, authenticity, and acceptance of responsibility.    

We focus our efforts on three strategic imperatives to: Shape Tomorrow’s Leaders, Be the Top University for Innovation, and Positively Impact Humanity.

Standards of Conduct, Polices and Procedures

In our academic, research, and creative pursuits, and in our daily work, we make decisions that have implications beyond ourselves. The university has developed an overarching Code of Conduct to serve as a resource for decision-making and to ensure that our students, faculty, and staff have the necessary tools to act ethically and in compliance with regulatory requirements. This Plan was created to guide our campus constituents in understanding the importance of compliance, where to find the appropriate information and where to report suspected wrongdoing.

The campus strives to foster confidence and being comfortable to reasonably question and engage with colleagues about correct and ethical courses of actions, as established under the law and under campus policy. When employees are aware of an alleged violation, we take appropriate steps, including steps to self-report, seek guidance, and/or use other reporting options.

Our guiding principles, laws and policies are set forth in these documents:

Policies are governing documents for campus-wide topics. The process for which policies are created on campus is outlined in the Policy Proposal & Adoption Policy. The Office of Integrity and Compliance reviews policies on an established ongoing timeline to ensure relevancy and accuracy.

Oversight and Accountability: CU Boulder Ethics and Compliance Framework

Chancellor

The Chancellor is ultimately responsible for the campus ethics and compliance program and reports directly to the President of the University of Colorado System. To that end, the Chancellor has created the compliance program (“Framework”). The Framework and which compliance roles have been delegated are referenced and described in this section.

Executive Committee

The Executive Committee members are the Chancellor, the Provost and Executive Vice Chancellor for Academic Affairs, the Executive Vice Chancellor and Chief Operating Officer, and the Associate Vice Chancellor for Integrity, Safety and Compliance, as well as the Chancellor’s Chief of Staff and the Campus Managing Counsel. The Executive Committee’s role is to receive updates on the campus compliance and drive initiatives.

Office of the Provost and Executive Vice Chancellor for Academic Affairs

The Division of Academic Affairs is responsible for meeting the academic mission of the University of Colorado Boulder “to be a comprehensive graduate research university with selective admission standards offering a comprehensive array of undergraduate, masters and doctoral degree programs.” Our path in accomplishing this mission is articulated in the vision that the University of Colorado Boulder is a leading global comprehensive research university that will “… be a leader in addressing the humanitarian, social, and technological challenges of the twenty-first century by shaping tomorrow’s leaders, impacting humanity, and being the top university for innovation.” The compliance partners in Academic Affairs includes the Research and Innovation Office, Office of the Vice Chancellor for Student Affairs, the various Schools and Colleges, Academic Support Units, Office of the Vice Chancellor for Diversity, Equity, and Community Engagement, and the Ombuds Office.

Office of the Executive Vice Chancellor and Chief Operating Officer

The Senior Vice Chancellor and Chief Financial Officer provides leadership in campus financial management, and in its operational and planning activities. The Senior Vice Chancellor Division includes the offices of the Vice Chancellor for Infrastructure and Sustainability, the Chief Information Officer, the Senior Associate Vice Chancellor for Finance and Business Strategy and Deputy Chief Financial Officer, the Vice Chancellor for Strategic Relations, the Associate Vice Chancellor for Enrollment Management, the Chief Human Resources Officer, the Associate Vice Chancellor for Integrity, Safety and Compliance, the financial and capital construction management of Athletics, and their respective units.

Associate Vice Chancellor for Integrity, Safety and Compliance

The Associate Vice Chancellor for Integrity, Safety and Compliance serves as a resource to the programs and executives making compliance management decisions. The Associate Vice Chancellor is responsible for developing and updating this ethics and compliance plan; as well as convening the teams that execute the action items through the Campus Ethics and Compliance Working Group. The working group and associated teams meet regularly to discuss ethics and compliance matters on campus. For example, Monthly Ethics and Compliance Education Series, compliance website, campus risk assessment.

Lines of Communication

The University of Colorado Boulder framework follows the regular organizational reporting structures and includes the complementary values and ethics advisory committee, campus ethics and compliance working group and shared governance. The purpose of the committee framework is to serve as a resource to decision-makers across campus who are grappling with new ethical questions, competing values, and questions that may test our ability to act with integrity, courage, and respect. Each committee has pledged to offer a collegial, collaborative, and transparent approach to resolving these challenging situations. The Values and Ethics Advisory Committee and the Campus Ethics and Compliance Working Group sponsor dialogue around ethics and compliance issues. Specifically, creating guidelines for complex ethical issues, presenting at the Monthly Ethics and Compliance Sessions.

The university is also embracing and advancing our efforts to educate and, in the event of an alleged violation, utilize a “report and support” model of ethics and compliance. As such, the subject matter experts lead with a service and educational approach that supports an ethical and compliant response to difficult issues and policy violations.

To help create a compliant culture and prevent or avoid violations of policy, the campus uses a variety of tools, for example, but not limited to:

  • Pre-employment Screening Process
  • Disclosure of Interests
  • Fiscal Certification
  • Employee Criminal Background Check

Training, Communication and Outreach

Training

We implement and ensure compliance with university policies and procedures and Regent, state and federal laws, policies, and regulations through our organizational reporting structure and we will begin to include specific responsibilities in employee performance plans. We develop and continue to improve our policies, procedures and training programs to ensure expectations for ethical and compliance standards are adopted and clearly communicated.

Throughout the year, we promote on-going dialogue and awareness of ethical and compliance issues and each September during our annual “ethics and compliance” month. The campus also has many informal groups who exchange information related to ethics and compliance. For example, the Research Administrators Meet is an informal, grass-roots organization developed to facilitate networking, communication, and knowledge transfer by and between CU Boulder Research Administrators.

CU Boulder requires all new employees to take the online orientation training. Specific trainings include but are not limited to Discrimination and Sexual Misconduct Training, Fiscal Code of Ethics, Information Security and Privacy Awareness, etc.  The Office of Employee Relations provides trainings and works one-on-one with employees and supervisors to ensure that employees and departments understand their respective rights and responsibilities as governed by university policies and procedures, state rules and regulations, and state and federal law. We advise all employees in a fair and unbiased manner and treat all individuals who seek our assistance with respect and dignity.

Communication & Outreach

The campus compliance website is being updated to include easier and more searchable access to campus policies and procedures. The website will be comprehensive and will include links to all of our campus compliance partners’ websites. The monthly education series is currently communicated out through our website. News about compliance around campus and new policies will be posted and communication on the basic trainings and policies that are required depending on the role of the individual or their area of campus will also be presented.

A communication plan has been developed in partnership with Strategic Relations to communicate all campus wide compliance and policy initiatives on a specified timeline throughout the year.

Reporting, Non-retaliation and Enforcement

The university maintains an array of departments and policies that relate to reporting and investigating misconduct. The purpose of reporting is to correct and remedy violations, especially those that relate to employee misconduct, health and safety issues or issues related to the misuse of university resources. Individuals can report concerns or potential violations as follows:

  • Supervisors – this is the first option for reporting, and where we look to resolve the majority of issues.
  • CU EthicsLine – The reporting service is provided by EthicsPoint, an independent company that provides a way to anonymously report concerns involving fiscal misconduct, violations of state or federal law, serious or recurring violations of university policy, or gross waste of university funds or property. 24/7 reporting is available via a toll-free phone number (1.800.677.5590) or online (www.Ethicspoint.com). These reports are reviewed by the CU System Office.
  • Don’t Ignore It to receive reports of possible bias-motivated incidents, sexual misconduct, gender/sexual harassment, protected class discrimination, and crimes.

We are committed to protecting all individuals against retaliation for reports made in good faith. Retaliation is prohibited under federal and state law, as well as university policy. An employee who is determined to have knowingly fabricated, distorted, exaggerated or minimized the wrongdoing either to injure or to protect someone, including him or herself, may be disciplined.

Disciplinary procedures for classified and university staff employees to address unethical behavior or conduct that fails to comply with federal or state laws and regulations or University policies, including failures to comply with mandatory reporting requirements, are set forth in existing Human Resources policies, as well as applicable state law. As noted above, all University employees are subject to the Administrative Policy Statement Code of Conduct.

Monitoring, Auditing, Risk Assessment

Monitoring

The campus engages in frequent surveys and self-assessments to identify areas for improvement and areas of strength. The campus also enters into contracts for third party assessments of programs that require greater scrutiny. We also engage third parties to assist us in program reviews to identify areas where we can implement better business processes, which lead to higher compliance rates.

Risk Assessments

The Office of Integrity and Compliance provides ongoing campus compliance risk assessments. This report it then given to the Chancellor’s Cabinet. The risk assessment is used to identity our highest compliance risk areas so that appropriate resources are directed at them.

Office of Internal Audit and Campus Controller

The Department of Internal Audit is established within the University of Colorado by the Board of Regents. Its role and responsibilities are defined by the Board of Regents as set forth in the Internal Audit charter. The Audit Committee of the Board of Regents provides oversight of the Department of Internal Audit. The director of the Department of Internal Audit is appointed by the Board of Regents, reports functionally to the Audit Committee, and reports administratively to the president.

The Department of Internal Audit provides independent, objective assurance and consulting activity designed to add value and improve the university's operations. It helps the university accomplish its objectives by bringing a systematic, disciplined approach to the evaluation and improvement of university processes related to university-wide risk management, control, and governance.

The Campus Assistant Vice Chancellor and Controller is our campus liaison to the CU Internal Auditor. The controller assists campus departments with the audit process, which includes attending entrance conferences held by Internal Audit with the campus department, helping the department prepare the draft report to Internal Audit, setting realistic timelines and deliverables, etc. The Assistant Vice Chancellor and Controller also represents the campus at the Regent Audit Committee.

Continuous Assessment and Improvements

To ensure a state-of-the-art compliance program plan at the University of Colorado Boulder, this compliance plan is reviewed and updated each year. CU Boulder is a community of problem solvers with a commitment to continuous improvement. When CU Boulder finds that actions or policies do not support its commitment to ethical behavior and legally compliant programs, CU Boulder works to remedy wrongdoing as quickly as possible, including actions ranging from employee discipline and termination; holding students, faculty and staff accountable in accordance with the applicable code of conduct; and revising policies and procedures to support this program.