Compliance Program

1. Organizational Leadership, Culture, and Governance: Demonstrate a compelling “tone from the top” by instituting effective organizational vision, structure, oversight, communication, and governance. 

Standards and Procedures: Establish standards and procedures, policies, and guidelines to promote operational excellence through ethical behavior.

1. Right People, Right Roles: Hire and empower exceptional personnel. Grant and monitor appropriate authority to enable effective support of our mission. Promote recognition for exceptional work and ensure decision-making authorities are informed and knowledgeable about operations.
2. Education and Awareness: Communicate expectations of high ethical standards and adherence to policies, procedures, and other aspects of ethics and compliance. Provide training and education consistently, effectively and in a practical manner as appropriate to an individual’s role and responsibilities.
3. Program Evaluation and Guidance: Monitor and audit periodically to detect unusual results or non-compliant conduct. Establish and promote avenues for individuals to seek guidance or report potential non-compliant conduct without fear of retaliation.  
4. Consistent Enforcement of Standards and Discipline: Promote and consistently enforce standards and discipline throughout the organization. Establish a response to detected offenses and implement corrective action plans. Uniformly enforce standards through appropriate discipline to prevent similar conduct.
5. Response and Prevention: Respond appropriately to non-compliant acts to prevent further instances. Make any necessary improvements to reduce the risk of future noncompliance and perform outreach to re-align organizational culture. 

The Texas State Institutional Compliance and Ethics program follows a model based on the federal elements of an effective compliance and ethics program (see § 8B2.1).