Compliance, Ethics, and Integrity Program Overview

Compliance, Ethics, and Integrity (CEI) Defined

Compliance is abiding by applicable laws, regulations, and policies. It includes external entities such as the US Department of Education and the Northwest Commission on Colleges and Universities and internal bodies such as committees and departments. It is less about regulating individual behavior than it is about understanding applicable requirements that apply to PNWU and ensuring we meet them.

Ethics is a set of moral principles that govern an individual or a group. It is not enough to assume that individuals are inherently ethical and thus the institution overall is ethical. An organization must cultivate an environment of integrity, trust, responsibility, stewardship, respect, and communication, because policies alone will not stop wrongdoing.

Integrity is the quality of being honest and having high moral principles. It is an internal system that guides behavior and is a choice rather than an obligation. “It is doing the right thing even when no one is watching.”—C.S. Lewis

Compliance, ethics, and integrity contribute essential components to PNWU’s success by both mitigating risk and creating a thriving and inclusive working and learning environment. A robust CEI program helps develop and reinforce a shared set of values and expectations which strengthens personal integrity; all of which influences how we interact with one another to produce virtuous and effective practices.

The Seven Elements of the CEI Program 

The PNWU CEI Program is structured in accordance with US Sentencing Commission 

1. Standards, policies, and procedures 

2. Program oversight 

3. Education and training 

4. Communication and reporting 

5. Monitoring and auditing 

6. Inquiries and enforcement of standards 

7. Corrective or disciplinary action and incentives 

Standards, policies, and procedures
Decisions we make often have implications beyond ourselves. Standards or principles to guide decision-making are articulated in the PNWU Code of Conduct and PNWU policies and procedures are the tools we use for consistent and fair application of laws, regulations, and best practices. 

The Policy and Procedure Committee (PPC) is a function of the CEI program and assists with establishing, creating, and amending policy and procedure. 

Program oversight
The Board of Trustees is ultimately responsible for the CEI Program as set forth in the PNWU Bylaws. The CEI Program framework describes the structure, roles, and responsibilities delegated by the trustees to the Board CEI Committee and the Office of CEIS. Further, each unit of the institution (e.g., academic program, office, department, committee) has CEI responsibilities particular to their purpose. 

Education and training
Need-based CEI education and training is provided through various platforms and tailored to the audience/individual to enhance understanding, gain knowledge, and improve skills for continuous improvement in compliance, ethics, and integrity. Education and training are highly dependent upon role/job description and unit(s) (the office, department, program, or committee) to which the individual belongs. Some will be very specific to the PNWU CEI program operations (e.g., policy development and review, implementing corrective action, documenting compliance for reporting), others will be more general (e.g., creating and maintaining an ethical workplace environment). The Office of CEIS works collaboratively with units for delivery of education and training. 

Communication and reporting
The Program’s structure provides for official reporting and open lines of communication among the CEI Board Committee, the Office of CEIS, and the units of the institution. The Program’s web presence (PNWU.edu and MyPNWU) provides resources both external and internal to inform constituents about education and training opportunities; institutional CEI data summaries; and timelines/dates for audits and policy review, risk assessment/mitigation, and committee meetings. Contact information for those charged to address specific compliance elements is also provided. Across all platforms and in all interactions, the Program promotes professional, honorable communication that furthers a culture of compliance, ethics, and integrity. It promotes a speak up environment where employees are encouraged to come forward with concerns and retaliation is not tolerated. Even so, some situations may necessitate confidential or anonymous reporting. The Program provides for open, confidential reporting on PNWU.edu and MyPNWU. 

Monitoring and auditing
Regular ongoing self-assessment, self- and peer-reviews, and other methodologies employed to detect compliance risk issues are forms of monitoring (AKA internal auditing) conducted by and specific to the various areas of the institution. Each is designed to test for inconsistencies, duplication, errors, policy violations, missing approvals, incomplete data, and other possible breakdowns in internal controls. Independent, objective audits conducted by external entities occur on a schedule established cooperatively between the Office of CEIS and the CEI Committee of the Board. Audit results either confirm internal controls are in place and functioning as intended or identify weaknesses that need to be addressed. Plans for addressing weaknesses are cooperatively developed between the unit and the Office of CEIS and scheduled for regular review.  

Inquiries and enforcement of standards
Alleged violations of standards, principles, policies, procedures, laws, and regulations are acted upon immediately once known/reported. Trained personnel follow protocol for each step of the process beginning with initial analysis and evaluation of the allegation to determine credibility, available/necessary actionable steps, and the most suitable person to address the allegation; and if warranted, who will oversee and conduct an internal inquiry. Internal inquiries uncover and help correct improper activities before they attract government attention or lead to litigation, and signals to the PNWU community that standards are enforced. Written inquiry findings from the Office of CIES detail the who, what, where, when, why, and how. From that, a final objective and neutral report is written communicating whether misconduct occurred, and recommendation(s) for resolving the matter. 

Corrective or disciplinary action and incentives
The nature of the allegation determines the individual or body that will act on the findings in a final report. Remedial action must be proper and prompt and can range from changes to policy or procedure to employee disciplinary action, including termination. Confidentiality is paramount both in the inquiry and disciplinary process. Conversely, appropriate incentives are provided to those who consistently perform in accordance with the Program.