1. The University of Houston Institutional Compliance Program Rev July 2011

2. Institutional Compliance Program What Is It? Identifies compliance-related risks Evaluates/improves control measures to prevent non-compliance Offers employees confidential reporting mechanism for potential non-compliant issues

3. Institutional Compliance Program Why Do It? Mission Statement: To promote and support a culture at the University of Houston which builds compliance consciousness into the daily activities of the University and encourages all employees to conduct University business with honesty and integrity.

4. Institutional Compliance Program Administered by Institutional Compliance Committee with representatives from each major function of the University UH Institutional Compliance Officer is Robert Schneller 713-743-5858 rdschneller@uh.edu

5. Institutional Compliance Manual Located at the Risk Management Webpage http://www.uh.edu/af/riskmanagement/InstC omplliance.htm

6. Institutional Compliance Manual UH System Policy Mission and Goals Ethical Conduct Policy Institutional Compliance Committee Membership Roles and Responsibilities Confidential Reporting UH System Action Plan Risk Assessment Matrix High Risk Area Compliance Evaluations (restricted access) Training requirements

7. Institutional Compliance Program High-Risk Compliance Areas Academic Affairs Accreditation Advancement Athletics Contracts Administration Environmental Health & Safety Facilities Financial Aid Healthcare Billing & Confidentiality Human Resources Law Law Enforcement Purchasing Residential Life and Housing Sponsored Research Student Affairs Treasury/Financial Accounting

8. Institutional Compliance Program Roles and Responsibilities Institutional Compliance Officer – Establish system to build compliance consciousness into daily activities – Monitor compliance program activities – Coordinate Confidential Reporting System – Communicate with appropriate people regarding possible issues of non-compliance

9. Institutional Compliance Program Roles and Responsibilities Institutional Compliance Committee Members – Conduct risk assessment of compliance-related activities within areas of responsibilities – Develop and implement risk improvement action plans as needed – Facilitate specific training regarding compliance-related requirements within area of responsibility

10. Institutional Compliance Program Roles and Responsibilities All Managers and Employees – Maintain high ethical standards – Comply with laws, regulations and rules applicable to performance of their job – Report instances of possible non-compliance to manager or through confidential reporting system

11. Institutional Compliance Program Confidential Reporting of Potential Non-Compliance Administered by external vendor and may be contacted at http://www.mysafecampus.com or by calling 1-800-716-9007 http://www.mysafecampus.com Reporter may be completely confidential Allows reporting mechanism outside normal reporting relationships Good faith reporting has legal protection from retaliation Not to be used for employment issues such as complaints about wages, work hours, performance evaluations, discrimination or relations with managers – Contact Human Resources or Affirmative Action for these issues.