Compliance should facilitate an ongoing and meaningful conversation between students, faculty, and staff about legal and ethical behavior to foster a sense of purpose and ensure that the university has an effective program in place to prevent, detect and mitigate significant compliance and ethics risks.  The wheel-based model reflects the perpetual nature of this process.

Perform Risk Assessment: Develop and manage a process to identify and prioritize compliance risks

Develop Policies: Help others draft policies and develop and manage the policy process

Deliver Education: Help others develop training and other controls; Manage a training program

Enable Reporting: Develop and manage a reporting process to capture issues and help monitor effectiveness

Conduct Investigations: Help others investigate allegations and develop and manage the investigation process

Take Corrective Action: Help management determine appropriate corrective action