Policy on Regulatory Compliance

Tufts University views compliance with federal, state and local regulatory matters as a serious obligation. This responsibility rests with employees at all levels of the institution. Accordingly, each employee should become familiar with any pertinent regulations which govern teaching, research and administrative activities in his or her area of responsibility

Each Tufts University employee is expected to report any significant instance of suspected non-compliance with a regulatory matter to the appropriate University manager responsible for enforcement and monitoring. A “significant instance of non-compliance” is defined as any activity or circumstance that could result in the assessment of a monetary or civil fine, penalty, loss of funding or consent order by an external regulatory body. The Institutional Compliance Officer should be made aware of any significant instances of regulatory non-compliance by the individuals responsible for enforcement and monitoring to help assess the effectiveness of the University’s Compliance Program and for reporting purposes to the Trustee Audit Committee. Suspected non-compliance with regulatory matters specific to research misconduct are not covered by this policy and instead should be reported in accordance with procedures established by the Office of the Vice Provost.

Depending on the circumstances of non-compliance, individual managers responsible for compliance in their respective areas may need to confer with University Legal Counsel, the Vice Provost, University vice presidents, Sponsored Accounting, Public & Environmental Safety, the Institutional Compliance Officer and other appropriate offices.

It is the policy of Tufts University that any person is free to lawfully disclose whatever information supports a reasonable belief of suspected regulatory non-compliance. The University is committed to protecting employees from interference when making such disclosures. An employee may not retaliate against an employee who has made a disclosure and is also prohibited from directly or indirectly using the official authority of his or her position or office for the purpose of interfering with the right of an employee to make such a disclosure.

Situations may exist where individuals feel uncomfortable discussing non-compliance with regulatory matters with their supervisors or responsible managers. To assist with these particular situations, the University has an agreement with a 3rd party anonymous reporting provider, EthicsPoint, Inc, to maintain a Tufts University internet application and call center for individuals to report any concerns related to non-compliance with certain regulatory matters. The EthicsPoint’s application is designed to ensure that any communications will remain completely confidential in accordance with the wishes of individuals who make reports using this option. You may access this reporting option on the internet by clicking on the Tufts University/EthicsPoint Anonymous Reporting Hotline link under the Helpful Links section of the AMAS web page, the Anonymous Fraud Reporting link on the Finance Division web page, or by going directly to https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7182. Access is also available by dialing toll-free 1-866-384-4277.

Upon being alerted to an issue of regulatory non-compliance, responsible university managers will be contacted to investigate the matter and develop any action plans necessary to restore compliance. Audit & Management Advisory Services will be responsible for determining if the action plan has been implemented. Disciplinary action up to and including employment termination will be considered if it is determined that an individual deliberately circumvented compliance with a federal, state and local regulation or should have been aware of the requirement in the performance of his or her responsibilities but failed to comply.

Any significant and systemic issues related to non-compliance with regulatory matters which cannot be satisfactorily resolved through this process will be escalated to higher levels of management including, as appropriate, the Executive Vice President, Provost and the President.