COMPLIANCE & ETHICS PROGRAM EFFECTIVENESS
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1 COMPLIANCE & ETHICS PROGRAM EFFECTIVENESS FY2017 Metrics Audit & Compliance Committee, November 2017
2 C&E PROGRAM W&M must evaluate periodically the effectiveness of the organization s compliance and ethics program. Board must exercise reasonable oversight of the program and its effectiveness. 2
3 PROGRAM ELEMENTS 1. Policies 2. Organizational structure & CECO 3. Due diligence in hiring 4. Education/awareness 5. Monitoring & evaluating 6. Incentives & remediation 7. Risk analysis 3
4 POLICIES AND PROCEDURES Adopted 10 new institutional policies Amended 5 others 4
5 EDUCATION & INCENTIVES Significant activities: 2017 Haven Training COI training Clery Act education Improved accountability 5
6 PROGRAM ELEMENTS 1. Policies 2. Organizational structure & CECO 3. Due diligence in hiring 4. Education/awareness 5. Monitoring & evaluating 6. Incentives & remediation 7. Risk analysis 6
7 MONITORING & EVALUATION: 2017 ARMICS Assessment Survey on management of public resources; internal controls. 2,744 W&M and VIMS faculty and staff surveyed; 563 returned survey fully completed (approximately 20.5%). 7
8 ARMICS SURVEY: Awareness of Policies 8
9 ARMICS SURVEY: Code of Ethics 9
10 1 0 ARMICS SURVEY: Ethical Culture
11 ARMICS SURVEY: Ethical Culture 1 1
12 1 2 ARMICS SURVEY: Ethical Culture
13 MONITORING: Reports & Investigations Reviewing report data shows: Employee awareness of reporting mechanisms Employee confidence in investigation systems Whether misconduct is occurring Compliance staff activities 13
14 MONITORING & EVALUATION: FY 2017 Reports & Investigations Total 167 reports received Total 32 investigations conducted 14
15 ANNUAL COMPARISON Reports Investigations
16 TYPES OF ISSUES REPORTED Title IX 6 Retaliation Other discrimination Conflict of Interest Other HR 128 Other 16
17 EMPLOYEE REPORTS 52 reports in FY 2017 Report volume per 100 employees W&M = 2.08 Median = 1.4 reports* (range = *) * Navex Global 2016 survey data of 2,382 hotline and incident management clients 17
18 SUBSTANTIATION RATE The percentage of investigations of employee matters that resulted in a finding of a violation: 2017: 64% 2016: 47% 18
19 ANNUAL TITLE IX /VAWA DATA Number & Type of Title IX Violations Reported Discrimination/ Sexual Harassment FY17 FY16 FY15 Other (Exploitation, RV, Stalking, NCSC) Sexual Assault (NCSI/Fondling) 19
20 ANNUAL TITLE IX /VAWA DATA FY17 Sexual Harassment & Assault Response to Allegations Reported 11% 1% 21% Investigated [30] Remedial Action Taken [11] 8% Non Actionable [82] 59% Referred to DoS, HR, Dean/Chair [16] Other [1] 20
21 ANNUAL TITLE IX/VAWA DATA 21 sexual misconduct investigations 10 had a finding of at least one policy violation 1 Permanent Resignation prior to conclusion 1 investigation ongoing 21
22 TITLE IX/VAWA & LAW ENFORCEMENT 19 Title IX Review Team reports to Commonwealth Attorney* 8 investigations by WMPD 5 arrests *these reports describe the type of offense reported, the date of the offense (or approximate date); details of the report; whether or not there is a campus or criminal investigation (or describes no investigation due to lack of information or wishes of the reporting party) 22
23 Q1 TITLE IX/VAWA DATA Audit & Compliance, November 2017 Kiersten Boyce, Chief Compliance Officer/Title IX Coordinator
24 Q1 FY18 REPORTS 27 Reports Received 18 Title IX 6 Other discrimination/harassment (ADA, Race, Unknown) 1 Workplace Violence 1 FLSA/Wrongful employment termination 1 Code of Ethics 2 Retaliation (in conjunction with report of harassment) 2
25 FIRST QUARTER DATA COMPARISON Q1 FY18 Q1 FY All Reports TIX Reports All Investigations TIX Investigations Q1 FY
26 40 TITLE IX /VAWA DATA FY17 QUARTER BY QUARTER COMPARISON Q1 Q2 Q3 Q4 0 TOTAL REPORTS 4
27 TITLE IX /VAWA DATA FIRST QUARTER FY18 Allegations Reported by students, faculty, staff 4 6 Sexual Harassment Discrimination (Gender) Sexual Assault/Fondling Relationship Violence Stalking 5
28 TITLE IX /VAWA DATA FIRST QUARTER FY18 (JULY-SEPTEMBER) Disposition of reports (18 total): 2 investigated (OCR and policy/procedure investigation) 10 Non-Actionable (no jurisdiction, no investigation wanted by reporting party) 1 Referred to Law Enforcement (WPD) 5 Remedial Actions (no contact order, safety plan, further inquiry, facility improvements) 6
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