Compliance Committee Charter

I. Purpose

The Compliance Committee (the “Committee”) is a standing committee appointed by the President, on behalf of the Board of Trustees. The Committee shall have general responsibility to oversee the College’s compliance and ethics programs, policies and procedures. The purpose of the Committee is to: (i) oversee the College’s implementation of compliance programs, policies and procedures that are designed to respond to the various compliance and regulatory risks facing the College; and (ii) assist the Board of Trustees in fulfilling its oversight responsibility for the College’s compliance and ethics programs, policies and procedures

The oversight responsibility of the Committee shall not extend to planning or conducting audits, conducting investigations, or assuring compliance with relevant laws, the College’s Code of Ethical Conduct, or other relevant standards, including those imposed by any settlement agreements. These are the responsibilities of the officers of the College.

II. Membership, Structure and Organization 

1. Members. The general membership of the Committee shall include major compliance owners across campus and will include but not be limited to the Executive Director of Human Resources, the Comptroller, the Director of Compliance and Risk Management, the Vice President for Finance and Administration, the CIO, a Student Life Representative and the Title IX and 504 Coordinator.  The committee shall consist of at least two (2) officers of the College. The Director of Compliance and Risk Management and one other member shall serve as Committee Chairs. 

2. Meetings. The Committee shall meet as frequently as it determines to be appropriate, but not less than four (4) times per year. 

3. Delegation of Tasks. The Committee may establish subcommittees consisting of one or more Committee members, other directors or management to carry out such duties and/or tasks as the Committee may delegate.

4. Resources. The Committee shall not submit requests for resources; however, it is expected that departments with compliance resource needs will request them through the normal budget process.  The Compliance Committee is encouraged to voice their support for those requests when needed.   

5. Charter. The Committee shall annually review and reassess the adequacy of this charter and recommend any proposed changes to the President for approval.

6. Agenda, Minutes and Reports. The Chairpersons of the Committee shall be responsible for setting the agendas for meetings. The agenda and information concerning the business to be conducted at each Committee meeting shall, to the extent practicable, be communicated to members sufficiently in advance of each meeting to permit meaningful review. The Chairpersons of the Committee will report regularly to the Institutional Risk Committee of the Board of Trustees, on the Committee’s activities, findings and recommendations. The report to the Board may take the form of an oral or written report by the Chairpersons or by any other member of the Committee designated by the Chairpersons to make such report.

III. Responsibilities

The responsibilities of the Compliance Committee shall include:

1. Compliance Matters Generally. The Committee shall have oversight responsibility for matters of non-financial compliance, including the College’s overall compliance programs, policies and procedures, and significant legal or regulatory compliance exposure.

2. Compliance Programs, Policies and Procedures. The Committee shall oversee the College’s efforts to implement compliance programs in accordance with the Federal Sentencing Guidelines and monitor policies and procedures that: 1) respond to the various compliance and regulatory risks facing the College and 2) support lawful and ethical business conduct by the College’s employees. The Committee shall also monitor the College’s efforts to fulfill obligations arising from governmental or regulatory agreements, orders, or other similar documents.

3. Compliance Risk Assessment. The Committee shall conduct a risk assessment in order to prioritize review of compliance objectives to those that pose the most significant risk to the College, both from a severity and likelihood standpoint.

4. Review of Complaints. The Director of Compliance and Risk Management and the Executive Director of Human Resources shall serve as an internal reporting resource for reports of noncompliance.

5. Committee Evaluation. The Committee shall perform an annual review of its performance, including a review of compliance with this charter. The Committee shall report the results of the evaluation to the Institutional Risk Committee of the Board.