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               University Compliance Steering Committee Charter

 

1. University Compliance Steering Committee Mission Statement: New York University provides a supportive environment for scholars and students to create new knowledge and to engage in teaching, research, learning and the provision of health care. Integrity in our work and compliance with applicable laws and regulations is critical to our academic enterprise and the operations. The primary locus of compliance with applicable laws and regulations is in the academic and administrative units throughout the University, where the authority for policy development and the responsibility for implementation of compliance reside. The mission of the University Compliance Steering Committee (UCSC) is to promote excellence in all our compliance efforts to assure integrity and compliance with our legal, regulatory, and ethical responsibilities.


2. UCSC Composition: The members of the UCSC are the Provost, the Executive Vice President, the Senior Vice President for Health, the Deputy President, the Senior Vice President and General Counsel, the Senior Vice President for Finance and Budget, the Senior Vice Provost for Academic Policies, and the Senior Vice Provost for Research. The University’s Chief Compliance Officer serves as staff to the UCSC.  Other persons, such as the University Senior Vice Presidents and the Vice President of Audit and Compliance for the NYU Langone Medical Center, may be invited to attend meetings at which items relevant to their areas of responsibility or concern are raised.

 

3. UCSC Mandate: The UCSC is responsible for approving the University’s ethics, compliance, and training priorities and has oversight responsibility for the University’s compliance efforts, including fulfilling these priorities.  The UCSC is supported by the University’s Chief Compliance Officer and the University Compliance Officers Working Group. The UCSC serves as an open avenue of communication among senior management and with the various University Compliance Officers and the University’s Chief Compliance Officer on compliance issues.  The UCSC also advises the Chief Compliance Officer regarding compliance and related compliance risk issues and programs to be presented to the Audit and Compliance Committee of the Board of Trustees. 


4. UCSC Specific Responsibilities: The UCSC will meet at least quarterly with the Chief Compliance Officer to review, discuss and provide direction regarding:


a.       the University’s compliance environment and the substantive compliance initiatives for which the University’s academic and administrative units are  responsible;

b.      the priorities of the Office of Compliance and Risk Management and of the major units involved in compliance;

c.       the activities of the University’s Compliance Officers and their Working Group, chaired by the Chief Compliance Officer, including the School Liaisons to the Working Group.

d.      any significant compliance issues and related corrective action plans;

e.       reports of alleged compliance violations, including reports to the University’s Compliance Line, and any related investigations; and

f.       proposed new and revised compliance policies.

 

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[1] NYU Washington Square (including all NYU operations apart from the Langone Medical Center) and the NYU Langone Medical Center have separate compliance offices and programs, each of which has primary responsibility for compliance issues arising respectively at Washington Square and the Langone Medical Center. However, the University Compliance Steering Committee and the Compliance Officers Working Group have representatives for both compliance programs in order to: (1) ensure that all compliance issues are addressed; (2) facilitate coordination of their respective compliance activities, and (2) enhance collaboration on compliance issues that affect both Washington Square and Langone Medical Center operations.  

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