Compliance Guide

Stevens’ compliance functions are integrated into the operational units across the University, with compliance subject matter experts located in various divisions and offices. This permits operational units to identify and respond to compliance issues quickly. The University's Office of Risk and Compliance (ORC), through the Chief Compliance Officer, oversees and coordinates compliance activities across the University and supports divisional leaders and subject matter experts. ORC helps to identify compliance risks and ensure appropriate controls are in place to meet the University’s compliance obligations.

A number of Vice Presidents and other campus leaders, together with the Chief Compliance Officer, serve on the Risk and Compliance Steering Committee (RCSC), which meets at least quarterly to review compliance matters, identify compliance risks and assess the effectiveness of compliance programs in particular areas. The RCSC also advises the President and Cabinet on risk and compliance issues that may impact the University and recommends future initiatives to improve compliance performance and effectiveness. The Chief Compliance Officer updates the Board of Trustees’ Audit Committee about significant compliance matters on a quarterly basis. In addition, a separate Risk and Safety Committee meets regularly to focus on compliance issues involving safety and health issues, and reports annually to the RCSC.

Every member of the Stevens community must consider compliance with laws, regulations and University policies as part of their job. All employees should become familiar with the policies found in the University Policy Library as well as departmental policies and procedures relevant to their specific job responsibilities. As you conduct your work, identify potential compliance and legal issues and reach out for help from others within your office and the University offices listed below on a regular basis. In determining whether your work presents legal or compliance issues, it is important to consult with personnel at Stevens who have experience and training in the law and compliance and have responsibility for making judgments about whether or not a legal or compliance issue exists.

Reporting Ethical and Compliance Concerns 

If you identify a compliance or ethical concern, you are encouraged first to consult with your supervisor or another colleague within your department who has relevant subject matter expertise. If, for any reason, you are uncomfortable discussing the issue with your supervisor or colleague, you should report your concern directly to the ORC, the Office of Human Resources, the Office of General Counsel or, depending on the subject matter, one of the other offices listed below. Alternatively, you should feel free to report the concern to the Compliance Hotline which may be used to report complaints or compliance problems on an identified or anonymous basis.

Signature Authority

As part of our compliance efforts, we should all ensure that any legal obligation entered into on behalf of Stevens – whether styled as an agreement, contract, memorandum of understanding or other form of document -- is given appropriate legal and/or other review and is signed by a person authorized to incur obligations on behalf of Stevens. The Board of Trustees has adopted signature authority resolutions that specify the employees who are authorized to enter into various types of legal obligations. These resolutions are available from the Office of General Counsel. Please pause before signing any legal obligation on behalf of Stevens to ensure compliance with these requirements. 

Cooperation with Investigations, Audits and Inquiries 

To assist the University in investigating or otherwise dealing with compliance matters, it is critically important that all members of the Stevens community comply promptly with any request or inquiry from the Office of the General Counsel, ORC or the Office of Internal Audit. All members of the Stevens community are instructed that they should – and should feel free to – promptly comply with any such request or inquiry (including requests for documents or materials that would otherwise be considered confidential) in a direct manner and without the need to first notify or involve a supervisor or other person.

Whistleblower Protection

Stevens has adopted a policy known as the Conscientious Employee or “Whistle- blower” Protection Policy. Stevens will not take or permit to be taken any retaliatory action against an employee who reports a compliance concern as directed by this Guide.

Stevens has a number of offices that are available to work with you to support legal, regulatory and policy compliance and you should feel free to contact any of them as questions arise. Here you will find the contact information and a brief description of the functions for these offices.