About Us
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.
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
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.
Compliance Accountability Matrix
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.
Conflict of Interest Process and Oversight
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.
Ethics and Compliance Hotline Oversight and Facilitation
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.
Policies
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.
Compliance Services Office Ongoing Activities and Projects
The Office contributes to these campus compliance obligations and initiatives by coordinating with other offices and stakeholders:
Enterprise Risk Management
Contributes to the University-wide Enterprise Risk Management effort that identifies compliance (and other) risks across the University, and works to evaluate and mitigate risks.
Training
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
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
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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- Protection of Minors: Contributes to working group that manages the Protection of Minors Program, delivers trainings, answers questions, and provides programs with information and resources to facilitate compliance with the Protection of Minors Policy through a centralized Protection of Minors website.
- Privacy: Coordinate Privacy efforts by co-leading a Privacy Coordinating Committee and maintaining a centralized Privacy resource website.
- Drug Free Schools and Communities Act: Prepare the Biennial Drug and Alcohol Review Report.
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, Associate Vice President for Compliance Services
Nedra has led Boston University’s Compliance Services Office (CSO) since 2016, providing strategic leadership for university-wide compliance initiatives. CSO serves as a central resource for the Boston University community, partnering across the institution to clarify regulatory obligations, coordinate compliance activities, deliver training and education, investigate concerns, and identify and mitigate risk. As Associate Vice President for Compliance Services, Nedra oversees the office’s core functions as described above on this webpage, including administration of the University’s Ethics and Compliance Hotline, conflict of interest oversight, management of the policies website www.bu.edu/policies and co-ownership of the policy governance process, contributions to the University’s Enterprise Risk Management program, and oversight and management of many other University compliance initiatives focusing on areas around privacy issues, website accessibility, sexual misconduct prevention and harassment and discrimination prevention training, hazing prevention, employee onboarding, and protection of minors efforts. CSO reports to the Senior Vice President and General Counsel and the Board of Trustees Audit Committee.
Prior to joining Boston University, Nedra served as Director of Compliance and Ethics for the State University of New York (SUNY) System Administration. In this role, she established, coordinated, and maintained a University-wide Compliance function to serve the SUNY system of campuses, acting as a central resource for individual campus compliance efforts, maintaining the system-wide policy website, and helping with campus training efforts. She also held concurrent roles as system-wide Ethics Officer and Records Management Officer. Earlier in her career, she spent more than seven years in higher education administration at the University of Connecticut School of Law. Nedra earned her undergraduate degree, cum laude, from the University of Connecticut and her J.D. from the University of Connecticut School of Law.
Send Nedra an email
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.
Send Samantha an email
Shanika Coney, Compliance Coordinator
Compliance Services Office
125 Bay State Road, Boston MA 02215
(617) 358-8090
Email: comply@bu.edu
Email: policy@bu.edu
Prior to joining Boston University, Nedra served as Director of Compliance and Ethics for the State University of New York (SUNY) System Administration, where she also held system-wide roles as Ethics Officer and Records Management Officer. Earlier in her career, she spent more than seven years in higher education administration at the University of Connecticut School of Law. Nedra earned her undergraduate degree, cum laude, from the University of Connecticut and her J.D. from the University of Connecticut School of Law.
