About the Compliance Services Office
Mission Statement
The Compliance Services Office coordinates the University’s efforts to meet compliance obligations efficiently and effectively and fosters ethical behavior and a culture of integrity through reinforcement of Boston University’s Code of Ethical Conduct and Conflict of Interest Policy.
We fulfill this mission by:
- Supporting departments with a primary responsibility for compliance, and assisting the University’s Compliance Area and Operational owners with monitoring, identifying, and understanding new and existing compliance obligations.
- Providing safe, confidential, and effective mechanisms for asking questions and reporting about compliance and ethics issues.
- Collaborating with offices across the university to ensure that compliance matters are resolved in a manner that uphold community standards of integrity and ethical behavior.
- Promoting and facilitating the University’s confidential Ethics and Compliance Hotline, and assisting the Compliance Committee with oversight of case investigations and outcomes.
- Enabling access to the University’s Policies and Procedures through management of a central Policies webpage.
- Providing advice to the Boston University community on compliance and ethics issues.
- Assisting with the development and implementation of the University’s compliance training and education efforts.
In furtherance of our mission and activities, the Compliance Services Office endeavors to be knowledgeable, responsive, and ethical.
Compliance Services Office Activities
Compliance Services is a resource for the entire Boston University community. The Compliance Services Office supports the departments with primary responsibility for compliance and coordinates the University’s efforts to meet these obligations efficiently and effectively. Compliance Services is available to assist all members of the University community in clarifying obligations, assessing risk and prioritizing compliance projects, developing and providing training, maintaining lines of communication that allow anyone to report a concern, monitoring and assessing compliance efforts, and taking corrective action as necessary to address concerns.
Compliance Services Office Core Responsibilities
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Compliance Program |
Maintain a University-wide Compliance Program committed to meeting the legal obligations more efficiently and effectively through a compliance framework for communicating about and tackling compliance. The Framework includes six components: (1) clarifying obligations; (2) establishing priorities; (3) develop procedures; (4) provide training; (5) report and investigate concerns; and (6) monitor and correct course. |
| Policy Website
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Maintain the University’s central policy website www.bu.edu/policies and identify policy gaps, facilitate updates to existing policies with Policy owners as needed, monitor policy changes, provide information about the Policy and Procedure governance process, and communicate with the University community about policies. |
| Conflict of Interest Process and Oversight
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Facilitate and oversee the University’s annual conflict of interest disclosure process pursuant to the Conflict of Interest Policy governing financial, family, and organizational conflicts, and implement management plans as necessary. |
| Compliance Accountability Matrix
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Maintain a Compliance Accountability Matrix and inventory of compliance obligations which includes identifying responsible individuals and units charged with meeting compliance obligations. The matrix establishes campus ownership of compliance obligations in a transparent way. |
| Ethics and Compliance Hotline Oversight and Facilitation
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Oversee and facilitate the University’s Ethics and Compliance Hotline and assist with other non-Hotline reports made to the Compliance Services Office through email, phone, and referrals. CSO also consults on all investigations, prepares investigation reports, conducts some investigations, and prepares responses provided to the reporter at case closure. |
Compliance Services Office Ongoing Activities and Projects
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| Enterprise Risk Management (ERM)
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Contributes to the University-wide Enterprise Risk Management (ERM) effort that identifies compliance (and other) risks across the University, and works to evaluate and mitigate risks. |
| Training
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Assists with the implementation and management of the University-wide training on Sexual Misconduct Prevention and Harassment and Discrimination prevention taken by all employees and assists with the implementation of the student training managed by the Health Promotion and Prevention Office. Additionally promotes training and professional development of individuals on campus who have compliance responsibilities, and assists in assessing training gaps, and makes recommendations for future trainings. CSO manages the relationship with the University’s primary training content vendor. |
| Ongoing Monitoring
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CSO works closely with Internal Audit and Advisory Services, the Office of the General Counsel, Research Compliance, and other offices to monitor ongoing compliance efforts and determine resources needed to manage existing, changing, and new compliance obligations. CSO works to identify areas of compliance vulnerability and assists in managing and mitigating these vulnerabilities and risks along with campus compliance partners, and documenting processes. |
| Contribute to specific compliance obligations and projects with compliance partners across the University
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The Compliance Services Office contributes to a variety of compliance projects at the University. The projects can change year-over-year. The projects that CSO has remained consistently involved with for the past several years includes the following:
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Compliance Services Office Assistance
We work with compliance partners across the University to clarify obligations; coordinate compliance activities; support training and other educational efforts; investigate compliance concerns and identify, assess and mitigate risks. To that end, we offer a number of services to help assess and address compliance issues, including:
– Table top exercises: Guided discussion of simulated hypothetical scenarios to clarify roles and responsibilities for responding to incidents.
– Risk assessments: Discussion with key stakeholders to identify potential compliance gaps of concern and assess the risks presented by those gaps.
– After action reviews: Structured review or de-brief process to assess a recent incident, focusing on identifying what went well and what could be improved in responding to a similar
incident in the future.
The Compliance Services Office partners include the Office of the General Counsel, Internal Audit and Advisory Services, the Director of Health Privacy and Compliance, Research Compliance, Information Security within IS&T, and the Associate Director of Enterprise Risk Management and Planning. We encourage you to reach out to report any compliance concerns or to discuss any questions related to compliance obligations.
Compliance Services Office Staff
Nedra Abbruzzese-Werling, Associate Vice President for Compliance Services
Nedra has overseen Boston University’s Compliance Services Office since 2016. The Compliance Services Office (CSO) is a resource for the entire Boston University community that works with compliance partners across the institution to clarify obligations, coordinate compliance activities, support training and other educational efforts, investigate compliance concerns and identify, assess and mitigate risks. In her role, Nedra provides leadership and guidance in support of the University’s compliance efforts. As AVP for Compliance Services, Nedra is responsible for carrying out all of the office’s responsibilities as described above on this webpage, including CSO’s core functions of Hotline facilitation, conflict of interest oversight, and management of the Policies website. CSO reports up to the General Counsel and the Board of Trustees Audit Committee.
Prior to BU, Nedra facilitated compliance efforts for the State University of New York (SUNY) System Administration, where she served as the Director of Compliance and Ethics. Nedra’s duties at SUNY were to establish, coordinate, and maintain a University-wide Compliance function to serve the SUNY system of campuses, act as a central resource for individual campus compliance efforts, maintain the system-wide policy website, and help with training efforts. Nedra also served as the System-wide Ethics Officer and System-wide Records Management Officer. Prior to SUNY, Nedra worked for over seven years in higher education administration at the University of Connecticut School of Law. Nedra graduated from the University of Connecticut, cum laude, and received her J.D. from the University of Connecticut School of Law.
Samantha Khosla, Compliance Director
Samantha facilitates the daily operations of the Compliance Services Office (CSO) and supports the office’s mission to coordinate the University’s efforts to meet compliance obligations efficiently and effectively, and to foster ethical behavior and a culture of integrity through reinforcement of Boston University’s Code of Ethical Conduct and Conflict of Interest Policy. Samantha supports the Associate Vice President for Compliance Services with furthering the University’s Compliance Program and administering CSO’s core functions, projects, and initiatives in furtherance of its mission. Examples include assisting with investigations, monitoring for new laws and regulations and facilitating University efforts to comply with new obligations, and coordinating with offices around the university to follow up on reports received through CSO.
Samantha has worked for Boston University since 2009. Prior to joining the Compliance Services Office, she was Senior Director of the Office of University Faculty Governance. Samantha is a graduate of Boston University and the University of Toronto. She received her J.D. from Suffolk University Law School and is admitted to the bar of the Commonwealth of Massachusetts.
Shanika Coney, Compliance Coordinator
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Compliance Services Office
125 Bay State Road, Boston MA 02215
(617) 358-8090
Comply@bu.edu; Policy@bu.edu