Division of Employee Accountability
A key to the success of a decentralized compliance program is the identification of employees with compliance oversight and ownership.
![](https://compliance.ncsu.edu/wp-content/uploads/sites/119/2022/05/employee-accountability.jpg)
At each of the three Levels, identified employees will be evaluated and assessed on their commitment to achieving their compliance goals.
Level 1: Responsible Official
- Foster an atmosphere of ethics, integrity, and compliance
- Demonstrate commitment and visible willingness to let values drive decisions and articulate expectation that others should do the same
- Exercise effective compliance and integrity oversight and monitoring
- Integrate compliance and integrity expectations into performance evaluation criteria for direct reports with compliance obligations
- Ensure each Supervisor establishes, communicates, and evaluates compliance expectations for each Point-of-Contact employee
Level 2: Compliance Supervisors
- Ensure a corresponding Point-of-Contact employee is identified for each compliance area
- Establish and communicate compliance and integrity expectations to each Point-of-Contact and other direct reports
- Utilize metrics to assess Point-of-Contact employees’ efforts in achieving compliance and integrity objectives
- Identify opportunities for creating a culture of constant improvement
- Create an environment where employees feel comfortable reporting misconduct
- Emphasize that a commitment to compliance is more important than a commitment to results; the means are as equally important as the ends
Level 3: Unit Point-of-Contact (POC)
- The Point-of-Contact employee is the subject-matter-expert for their specific compliance area
- Develop and communicate PRRs, SOPs, and best practices for compliance and integrity attainment
- Develop subject matter information, resources and training content
- Coordinate with compliance partners to move the entire network towards the attainment of compliance and integrity objectives
- Strive for the attainment of the compliance and integrity objectives
- Act ethically in all endeavors and report known or suspected incidents of misconduct