About Us

Led by the university's chief compliance officer, the Integrity and Compliance Office is responsible to oversee and monitor the university’s overall compliance and ethics program, which includes administering its confidential compliance hotline and managing the university policymaking process. Read more about our purpose, mission, objectives, responsibility and services, reporting results, independence, authority, and confidentiality in our charter. The office assists management in facilitating institutional compliance and promoting a culture of compliance. Specifically, the office provides the following services (among others):

  • Assessing institutional compliance risks and risk mitigation strategies
  • Communicating compliance requirements, including by developing and distributing compliance research memos on various laws and requirements
  • Coordinating meetings and task forces to address campus-wide compliance issues and facilitate management decision-making
  • Creating compliance assessment tools to evaluate compliance with specific areas of the law
  • Facilitating training programs
  • Identifying emerging laws and regulations, including documenting their requirements and analyzing their applicability to the university
  • Managing and promoting an anonymous compliance hotline to facilitate reporting of compliance concerns
  • Publishing templates and guidance for creating compliance program documents

BYU’s compliance program is centrally coordinated by the Integrity and Compliance Office, but responsibility for complying with federal and state laws and regulations and university policies is distributed across campus. As such, university compliance issues are managed in coordination with unit experts or compliance liaisons and compliance committees. Responsibility for implementation of compliance policies, procedures, and practices resides with management.

The Integrity and Compliance Office consists of the chief compliance officer, policy manager, investigations manager, compliance analyst, communications specialist and training coordinator, project specialist, dedicated attorneys, and student research associates. Members of the compliance team work closely with university leaders and others across campus to identify legal requirements, establish policies and procedures, communicate compliance information, conduct trainings, monitor compliance with applicable laws, and keep governance groups informed about the state of compliance. In overseeing the university’s compliance program, the Integrity and Compliance Office coordinates regularly with Risk Management and Safety and the Office of the General Counsel.

History

BYU’s compliance structure was formally established in 2005 under the direction of President Cecil O. Samuelson. Prior to that time, the university had various activities and procedures in place to comply with relevant laws, but these compliance efforts were somewhat ad hoc and largely decentralized.

In September 2004, BYU’s Internal Audit Services published an issue paper identifying the need for a formal university compliance function given the significant regulatory requirements and complex legal environment in higher education. The paper recommended adoption of a compliance program and enterprise risk management model as well as appointment of a university compliance officer and university risk management committee. Shortly thereafter, a working group was chartered to research and recommend an organizational structure and implementation plan.

In April 2005, the working group published its recommendations, which included the following:

  1. Appoint a university compliance officer and form the university Office of Compliance and Audit.
  2. Appoint a university executive compliance and risk management committee.
  3. Realign Risk Management and Safety reporting to the administrative vice president (subsequently this reporting was realigned to the Office of the General Counsel).
  4. Reinforce the responsibility of line management for compliance and strengthen the oversight responsibility and capability of the campus compliance committees.
  5. Establish an effective reporting process.

In response to the recommendations, the university named David Galloway, executive director of Internal Audit Services, as BYU’s first compliance officer and charged him to lead the newly formed Office of Compliance and Audit. Additionally, the university established a compliance oversight committee known as the Executive Risk Management and Compliance Committee or ERMCC. The ERMCC directs the university's compliance program.

In 2009, recognizing the need for additional dedicated legal support, the Office of Compliance and Audit repurposed a full-time information systems auditor position into a full-time attorney position to focus exclusively on compliance issues. A compliance attorney was hired in 2010; two years later, the office focused one of its financial auditors on compliance assessments.

In November 2015, following the retirement of David Galloway and a period of interim leadership, David Petersen was appointed as the new university compliance officer, while also retaining his duties as director of Risk Management and Safety. At the same time, the department was renamed Risk Management, Safety, and Compliance.

The compliance office has continued to evolve and grow to better meet university needs. In 2016, the office hired a part-time office assistant to help with administrative needs and special projects, and the compliance auditor position was repurposed to hire a second compliance attorney. In 2017, given some organization changes in the administration of BYU's workers' compensation program, another full-time position became available that was allocated to the role of a compliance program manager.

In 2019, BYU created a standalone office for compliance, policies, and ethics, which was named the Integrity and Compliance Office. Sarah Campbell was appointed as the university's chief integrity and compliance officer and director of the new office. She became the first full-time compliance officer for BYU.