Administration of the Compliance Program
Written Policies and Procedures
SUNY Downstate's Compliance Program, including the Code of Ethics and Business Conduct serves as the central policy to outline Compliance administration. Additional policies and procedures to supplement the program are executed as needed.
Oversight Responsibilities
The VP-OCAS shall be responsible for the day-to-day management and administration of this Program. In addition, the President shall designate certain employees to serve on a Compliance and Audit Oversight Committee ("CAOC"). The CAOC shall assist the VP-OCAS in the administration of the Program, including without limitation, the investigation of complaints, as requested by the VP-OCAS or the President. The CAOC shall meet periodically.
All Department Heads are responsible for adherence to this Program in their respective departments.
Employee Training
SUNY Downstate recognizes the importance of communicating effectively its Code of Conduct and applicable Federal and State regulations to all of its employees and agents. Thus, it is the intent of Downstate to require all new hires to be appropriately trained as part of the orientation program provided to new employees of Downstate. Ongoing Compliance training shall be incorporated in the Annual Mandatory Education program provided by Human Resources. Additionally, periodic educational programs on specific areas of compliance will be administered as needed.
Reporting System / Open Lines of Communication
Employees and faculty are required to come forward with any information regarding an actual or possible violation of this Code or Downstate Policy and cooperate fully in the investigation of any alleged violation.
A Compliance Line has been established through which workforce members must report - to the VP-OCAS - any potential violations of law or deviation from compliance standards. All reports to the Compliance Line are confidential and may also be made anonymously. Reports to the Compliance Line may be made orally by calling 877-349-SUNY (7869) or via a web-based report by clicking on the "Compliance Line" link.
Enforcement and Discipline
SUNY Downstate recognizes the necessity to enforce the standards and procedures of its Compliance Program and to discipline those employees who violate the Program, those who negligently fail to detect an offense, and/or individuals who refuse to cooperate with compliance initiatives /investigations.
Monitoring and Auditing
SUNY Downstate will implement steps to monitor compliance with the Program. This will include monitoring and auditing to determine whether the Program is being adhered to and whether it is successfully serving its intended purpose. Compliance monitoring and auditing are aimed at ensuring adherence to general compliance policies and applicable federal and state laws and regulations.
Non-intimidation / Non-retaliation
Good faith participation in Downstate's Compliance Program is required of all workforce members. As such, intimidation or retaliatory behavior for reporting of concerns or cooperation with Compliance initiatives will not be tolerated. Individuals engaging in intimidating or penalizing conduct will be subject to disciplinary action.
Response and Prevention
If an offense occurs and is identified, it is the policy of Downstate to respond appropriately to the offense and to enjoin any further similar offenses.