Institutional Compliance Program Overview

The Institutional Compliance Program collaborates with university stakeholders, including subject matter-specific compliance functions embedded across the university, to support Yale’s faculty and staff in meeting their compliance obligations, and promote a culture of ethics and compliance with applicable laws and regulations.   The Program accomplishes this through the development, implementation, and maintenance of the following initiatives.

Compliance Program Framework 

The Framework articulates eight elements necessary for the establishment and maintenance of an effective program, and defines three categories of responsibilities—operations, compliance, and senior leadership— as they relate to each element.  It provides a common set of basic standards from which the university’s various compliance leaders can operate, and encourages compliance functions to conceptualize, plan, execute, measure, and report on activities in a consistent manner.

Requirement and Responsibility Matrix 

The Matrix captures the breadth of Yale’s externally imposed compliance obligations.  It provides a roadmap to compliance at Yale, and identifies compliance function leaders, with responsibilities relative to specific sets of laws and regulations applicable to Yale, with whom the Program collaborates.

Risk Assessment and Planning

A periodic process undertaken in partnership with the Offices of Enterprise Risk Management and University Auditing to identify, assess, and prioritize risks facing Yale.  Risk assessment results guide Program priorities. 

Program Evaluation 

An in-depth process for gathering and reviewing information related to compliance practices for a particular regulatory area or compliance function.  It is organized according to the Framework, and provides a structured way to highlight program strengths, and identify opportunities for improvement.  Evaluation results provide a way for Yale’s leaders to make risk tolerance and resource allocation decisions relating to compliance, and provide compliance personnel with analysis and structure around which they can develop work/mitigation plans and progress reports.

Monitoring and Reporting 

Information is reported in multiple ways through many channels within Yale.  The Program is responsible for establishing and maintaining processes to pull information out of organizational silos and give management a comprehensive view of compliance performance across the university.

Leadership Reporting

The Program reports periodically to university management and the Audit Committee of the Yale Corporation to ensure that Yale’s officers and trustees are well-informed regarding the university’s compliance program.

Other Initiatives

Offices across Yale develop, implement, and maintain an array of structures, practices, and processes designed to support compliance with an assortment of laws and regulations.  The Program provides advice to these offices as needed to support compliance initiatives, including the following:  

  • review of roles, responsibilities, structures, and practices related to specific compliance risks;
  • development of policies, procedures, and other documents;
  • development of training initiatives and other efforts to foster learning and open communication related to compliance matters;
  • efforts to right-size and streamline compliance controls to minimize burden, including through integration into business processes; and
  • addressing responses to adverse events, allegations or instances of non-compliance, and regulatory contacts relating to enforcement of legal or regulatory requirements.