1.0 PURPOSE

To fulfill the requirements of the Wheeling Jesuit University Compliance Program, the University will promote the program, training initiatives and communications on the requirements of the program and Compliance Inventory, the process of reporting non-compliance and participating in audits and investigations.

2.0 POLICY

2.1 Policy Statement

1. The University Compliance Coordinator, in conjunction with the Compliance Team, will identify training and  development needs to support the Compliance Plan. The Compliance Coordinator will:
• Serve as a resource for University-wide compliance initiatives.
• Develop and promote training programs for the University in support of the Compliance Plan and determine which employees require mandatory training.
• Develop hand-outs and communications to promote University compliance.
• Monitor and record attendance, assess the overall effectiveness of the training, and post continuing, voluntary, education and communications in the areas of compliance.
2. The University Compliance Coordinator, in conjunction with the Compliance Team, will establish training for internal auditors to assess University-wide compliance efforts.
3. The Compliance Team will promote the program through University-wide communications including emails, posters, websites and letters.
4. The Compliance Team will develop, through functional experts, positive, proactive, communications plans in the event of a confirmed instance of non-compliance.

2.2 Definitions

1. Internal Auditors – In the absence of an external audit, the Compliance Team will conduct internal audits of the Compliance Inventory. An external audit will suffice in lieu of an internal audit for the year in the compliance area in which it is completed. Auditors may not audit their own compliance areas.
2. Training – Training will be designated for employees who are assigned to or given specific responsibilities in the Compliance Inventory. Training may be designated as mandatory (required) or voluntary (suggested but not mandatory).
3. Communications – Written and oral means of promoting the program, employee involvement and employee participation in the process.

2.3 Training

1. Training will be posted through the Human Resource office and communicated to all employees via email.  There will be training throughout the fiscal year with a particular emphasis on Summer Professional  Development.
2. Individuals will be informed if training is mandatory for their position; they can also make a self- determination based upon their job description.

2.4 Communications

1. Communications will be on the Human Resource website, a designated Compliance website, distributed in handouts and office posters, University-wide emails, and internal University newsletters.
2. Communications plans will be formulated through the appropriate functional expert to diffuse reported instances of non-compliance and maintain the University’s position in a positive light.

2.5 Auditing

All auditors must complete audit training. Such training may be offered internally or externally. Employees may not be assigned to an audit absent audit training unless they are designated as “trainees.”

2.6 Authorization

The authorization for this policy emanates from the Wheeling Jesuit University Board of Directors; it cannot be changed or modified absent the express written consent of the Audit Committee.