Ethics and Compliance Overview

Ethics and Compliance Leadership Committee: At its core, the ECP remains the personal responsibility of every member of the CMC community, and particularly of its leaders. The academic and administrative departments throughout the College retain the responsibility for policy development and the implementation of compliance within their respective areas. The Ethics and Compliance Leadership Committee (“ECLC”) serves to direct CMC’s overall compliance efforts and to insure their alliance with CMC’s vision, mission, and values.

The ECLC comprises the President of the College, all Vice Presidents of the College, the Dean of the W. M. Keck Department of Science, the Director of Human Resources, the Director of Athletics, the Dean of Students, the Chief Technology Officer, the Chief Civil Rights Officer, the Assistant Vice President for Investigations, the Director of Academic Planning, and any other members the ECLC deems advisable. The ECLC is responsible for approving the College’s ethics, compliance, and training priorities, and has oversight responsibility for the College’s compliance efforts, including fulfilling these priorities. As part of these efforts, the ECLC will oversee an ethics and compliance risk and/or program assessment every two years or as otherwise appropriate to identify emerging risks, review the sufficiency of ongoing mitigation activities and otherwise inform ECP activities and priorities.

An important element of CMC’s ECP is the continuing training and education of our community on application of CMC’s core values, and individual obligations under applicable legal requirements and institutional policies.

CMC is committed to fostering dialogue across and among faculty, students, staff, and the administration through multiple channels. Administrators and academic leaders are expected to maintain an environment that promotes open communication without fear of any retaliation.

CMC’s ECP includes ongoing efforts to assess, evaluate and monitor compliance with the ECP. The nature, extent, and frequency of these activities depend on a variety of factors, including new regulatory requirements, changes in business practices, and other considerations.

Monitoring and assessment activities are conducted annually, and results are reported to the Audit Committee of the Board of Trustees.

CMC’s ECP is coordinated with the College’s relevant disciplinary procedures to impose any appropriate disciplinary sanctions for members of our community who violate the law, regulations, or institutional policies. Although each situation is considered on a case-by-case basis, the College imposes discipline to address inappropriate conduct and to deter future violations. In addition to imposing appropriate disciplinary action, the College also seeks to assess whether a violation may be due in part to gaps in the College’s policies, training, procedures, or other controls. If so, the College is committed to implementing corrective measures to enhance its controls to prevent further violations.