Texas Southern University is committed to conducting business consistent with applicable laws and regulations and to promoting high standards for ethical conduct in all employees. This commitment is evidenced through the establishment of the Office of Institutional Compliance, which is charged with implementing an effective Compliance Program for Grants Management and Contract Services. To achieve this objective, the Office of Institutional Compliance will follow the guidelines established by the United States Sentencing Commission that clearly outlines seven (7) components for establishing an effective compliance program. The key components are as follows:

1. Establish compliance standards and procedures that are reasonably capable of reducing the prospect of noncompliance by employees and faculty.

2. Assign high-level personnel in the organization the responsibility of overseeing compliance with such standards and procedures.

3. Exercise "due care" not to delegate substantial discretionary authority to individuals who the organization knew, or should have known through the exercise of due diligence, had a propensity to engage in illegal activity.

4. Effectively communicate compliance standards and procedures to all employees by requiring participation in compliance education and training programs.

5. Take reasonable steps to achieve compliance through the use of monitoring and auditing systems that are designed to detect noncompliance and by having in place a mechanism for reporting possible misconduct, fraud, abuse and noncompliance.

6. Establish and enforce standards through appropriate disciplinary mechanisms.

7. Take reasonable steps to respond appropriately to detected offenses and to prevent further similar offenses.