Compliance and Ethics FAQs

Compliance and Ethics Program

1.      What is a Compliance and Ethics Program?

A Compliance and Ethics Program is a program designed to protect the Stanford University Community and its resources. It strives to ensure ethical, professional and legal standards of behavior.

2.      Who is part of the Compliance and Ethics Program?

All faculty, staff, students, members of the Board of Trustees, University Officers and affiliates, are part of the Compliance and Ethics Program.  Moreover, consultants, vendors, contractors, volunteers and others who associate with the University are also part of the Compliance and Ethics Program. 

3.      Who sets the “tone” of a Compliance and Ethics Program?

The tone of a Compliance and Ethics Program is set "at the top” by Senior Management.   John L. Hennessy, President of Stanford University, said, "As a member of the Stanford University community, each of us is responsible for maintaining the highest ethical standards and performing activities with the utmost integrity and fairness."  

4.      Why have a Compliance and Ethics Program?

The purpose of a Compliance and Ethics Program is to protect the Stanford University Community members and its resources. It promotes the University values of respect, integrity, honesty and fairness and strives to integrate these values into its daily and long-term decisions and actions related to its teaching, research and business practices.                             

5.      What are the elements of an effective Compliance and Ethics Program?

The elements of an effective Compliance and Ethics Program are:

1. Standards and procedures
2. Governance, organization and reporting
3. Efforts to include only personnel who have engaged in appropriate conduct
4. Training and education
5. Program monitoring and auditing, evaluating program effectiveness, and systems for reporting suspected wrongdoing
6. Consistent enforcement and appropriate discipline
7.  Responding to noncompliance and modifying the program as necessary.

6.      Who is the Chief Compliance Officer?

D. Richard Moyer, Associate Vice President for Audit, Compliance and Privacy for Stanford University and the Stanford University Medical Center, is the Chief Compliance Officer. 

7.      Who is a member of the Stanford Community?

All faculty, staff, students, members of the Board of Trustees, University Officers, and affiliates, consultants, vendors, contractors, volunteers and others who associate with the University are members of the Stanford Community. 

University Code of Conduct and Policies

8.      What is the Stanford Code of Conduct?

The Stanford Code of Conduct is our guide to ethical, professional and legal standards of behavior. Central to this code is the principle of treating others with respect, integrity, honesty, and fairness.

9.      What is the responsibility of Faculty, Students and Staff at Stanford as it relates to the Code of Conduct?

Read the Code of Conduct and use it to guide your behavior. As a community we strive to integrate the values of respect, integrity, honesty, and fairness into our teaching, research, and business practices. We are individually and collectively accountable for our behavior.

10.  Which University policies apply to the Stanford Community?

Many University policies and guidelines affect the Stanford Community. They reside in the Stanford Code of Conduct, the Administrative Guide, the Faculty Handbook, and the Research Policy Handbook. A list of University policy documents can be found at http://www.stanford.edu/about/administration/policy.html.

Individual schools and departments also may maintain additional policies. Such policies, however, do not override university-wide policies.

Compliance and Ethics Helpline

11.  What is a Compliance and Ethics Helpline?

A reporting system by which an organization’s employees and agents may report concerns or seek guidance confidentially or anonymously regarding potential or actual misconduct without fear of retaliation.

12.  What is Stanford’s Compliance and Ethics Helpline?

Stanford’s Compliance and Ethics Helpline is a reporting mechanism that can be used by members of the Stanford Community who have concerns regarding misconduct or inquiries regarding compliance and ethical behavior. Concerns and inquiries can be reported confidentially, anonymously if desired, and resolution will be made by knowledgeable individuals. The University will not tolerate retaliation for raising concerns in good faith.

13.  What are Stanford’s systems for reporting wrongdoing?

As with any compliance concern, the University’s Office of Audit, Compliance and Privacy is available for reporting concerns through its helpline telephone (650-721-2667), email (compliance@stanford.edu), and online web submission form (helpline.stanford.edu), anonymously if desired. A member of the community could also reach out to their Director, Supervisor, the Office of the General Counsel, Office of the Ombuds or University Human Resources.

Conflict of Interest / Commitment

14.  What is a Conflict of Interest?

Stanford faculty and staff owe their primary professional allegiance to the University.  A conflict of interest exists if an independent observer might reasonably question whether an individual's professional decisions or actions at Stanford are influenced by a personal financial interest. 

15.  What is a Conflict of Commitment?

Stanford faculty and staff owe their primary professional allegiance to the University.  An actual or perceived conflict of commitment can arise when faculty members and staff attempt to balance University responsibilities with external activities--such as consulting, public service or pro bono work.  Conflicts of commitment usually involve issues of time allocation.

Financial Fraud, Waste and Abuse

16.  What is Fraud?

Fraud is intentionally, knowingly and willfully attempting to execute a scheme to falsely obtain payment from a federal, state or other governmental organization. Fraud involves knowingly perpetrating a scheme to defraud a governmental agency or Stanford University or any of its affiliates.

17.  What is Waste?

Waste is spending that can be eliminated without reducing quality of the service or product. Waste entails carelessly using governmental resources or the resources of Stanford University or any of its affiliates.

18.  What is Financial Abuse?

Financial abuse is improper behavior or billing practices that create unnecessary costs. Abuse is improperly using governmental resources or the resources of Stanford University or any of its affiliates so as to raise the costs of a service or product.

Uniform Guidance

19.  What is the effective date of the Uniform Guidance for Procurement at Stanford?

For non-Federal entities that are nonprofit organizations or institutions of higher education, such as Stanford, there is a one-year grace period for implementation of the procurement standards in the Uniform Guidance. Stanford will continue to comply with procurement standards outlined in OMB circular A-110 for one additional fiscal year that begins after December 26, 2014. Hence, Stanford will comply with the new guidance in fiscal year 2017, i.e. beginning September 1, 2016.

Americans with Disabilities Act

20.  Why does Stanford University need to comply with the Americans with Disabilities Act (ADA)?

Title I of the ADA requires employers with 15 or more employees to provide qualified individuals with disabilities an equal opportunity to benefit from the full range of employment-related opportunities available to others. In addition, Title III requires public accommodations to comply with basic nondiscrimination requirements that prohibit exclusion, segregation, and unequal treatment.