Institutional Responsibility

Each member of The Texas A&M University System is responsible for establishing an organizational culture that encourages ethical conduct and compliance with its legal obligations. Each member is responsible for complying with all applicable federal and state laws, and for meeting and complying with any reporting requirements required by law.

All members are required to establish an infrastructure to systematically identify and address risks so that faculty and staff are aware of their ethical and compliance responsibilities.

Each member will appoint a compliance officer (CO).  If other than the CEO, the designee will have direct and regular access to the CEO. With the assistance of the CEO and the member’s committee, the CO will act to implement the compliance plan. Each member CO will also provide a report to the SECO concerning compliance activity and processes prior to each regularly scheduled board meeting.

Each member will appoint a compliance committee chaired by the CEO or designated CO. The purpose of the committee will be to develop a compliance plan concerning each member’s operations. The compliance plan will address how the member systematically addresses risk, identifies emerging risk and will monitor the effective mitigation of that risk. This plan will be approved by the CEO and the SECO. The compliance committee will meet quarterly to address mitigation of risk, to provide appropriate resources for compliance and to ensure appropriate action for noncompliance issues brought to its attention.

Reporting Obligations

Each member is responsible for complying with all applicable federal or state reporting requirements. The reporting obligations set forth below are to fulfill the purposes of this regulation, to enable the  A&M System and each member to do a risk assessment to determine if additional resources should be allocated and to assist the member to respond as needed. These requirements do not replace, change or modify these applicable reporting requirements or any other action required of a member under federal or state laws or regulations.

The CO will report to the SECO compliance processes put into effect under the compliance plan for the SECO’s review.

The CO will promptly report to the CEO and SECO any suspected compliance violation that has caused or poses an imminent risk of injury or harm to persons, property or the surrounding community, or reputational harm, as soon as possible after discovering or receiving the report of the suspected violation. In coordination with the SECO, the CO will (a) conduct a compliance program investigation, or (b) monitor the investigation conducted by an appropriate member entity of the suspected violation(s) and, as appropriate, make written findings and recommendations to the member’s CEO or designee and SECO.