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Institute Compliance Program

The mission of the California Institute of Technology is to expand human knowledge and benefit society through research integrated with education. We investigate the most challenging, fundamental problems in science and technology in a singularly collegial, interdisciplinary atmosphere, while educating outstanding students to become creative members of society. As an institution dedicated to that mission we expect adherence to high standards of ethical behavior.   Accordingly, the Caltech Code of Conduct provides guidance to the conduct of faculty, staff, and agents.

Caltech promotes an organizational culture that encourages ethical conduct and a commitment to compliance with the law, and exercise's due diligence to prevent and detect criminal conduct.

1. The following principles are the standards of ethical behavior required of Caltech faculty and staff:

  • Faculty and staff are expected to obey all federal, state, and local laws, including, but not limited to, those pertaining to equal opportunity, non-discrimination, and harassment.

  • Faculty and staff must abide by Caltech's Conflicts of Interest Policy.

  • Faculty and staff must maintain the confidentiality of information as required under Caltech's policies or applicable law, including the confidentiality of personnel and student records, and proprietary information.

  • Faculty and staff should report illegal conduct or ethical standards violations, as well as violations of Institute policy, by contacting a member of management, Human Resources, or the Office of General Counsel or by calling the Caltech Hotline at (626) 395-8787.

  • Retaliation against an employee who has in good faith reported an alleged unethical or unlawful practice will not be tolerated. The Institute has adopted a Whistleblower Policy that prohibits retaliation.

Questions concerning behavior should be directed to one's supervisor, Human Resources, Audit Services & Institute Compliance (ASIC), or the Office of General Counsel (OGC). Supervisors seeking guidance should contact the same offices.

2. Caltech has standards and procedures that prevent and detect criminal conduct and encourage ethical conduct and compliance with the law.

  • Caltech maintains policies and procedures emphasizing good business practices and internal controls. Faculty and staff are expected to comply with the policies and procedures.

  • Institute trustees, officers, faculty, and staff identified as "disqualified persons" under the IRS Intermediate Sanctions regulations annually disclose potential conflicts of interest. In addition, officers, faculty, and staff participate in an annual conflict of interest disclosure process.

  • Purchasing Services requires that vendors certify that they are not on the government's excluded party list. Purchasing Services verifies certifications from new and large volume vendors.

  • The Institute maintains a Risk Management Council that oversees compliance for all major regulatory areas. Each area has its own documented policies and procedures to address regulatory requirements.

  • Campus and JPL compliance matrices document key compliance risk areas at Campus and JPL, and the cognizant policy office and officer/key contact responsible for ensuring compliance with applicable laws and regulations. Internal compliance assessments are developed and aligned with the compliance risk areas outlined in the Campus and JPL Compliance Matrices. The assessments capture management's written policies and procedures, general and specific compliance training provided to employees, and the extent and reach of management's monitoring activities implemented to meet compliance requirements.

3. The Board of Trustees is knowledgeable about the content and operation of the Institute Compliance Program, including its implementation and effectiveness.

  • The Board of Trustees has assigned responsibility for compliance oversight to its Audit and Compliance Committee.

  • The Institute maintains an Institutional Compliance Officer, who is assigned responsibility for ensuring that compliance programs for all major regulatory areas are established and maintained.

  • Executive oversight is provided by the Institute's Administrative Management Council.

  • Governance functions are in place to evaluate the extent of management's controls and monitoring processes and ensure they adequately address compliance requirements, and follow-up with management when compliance gaps are identified to ensure appropriate corrective action.

  • Periodically, the Audit and Compliance Committee receives reports on major compliance areas.

4. The Institute takes reasonable measures to exclude personnel from positions of authority whom the organization knows have engaged in illegal activities or other conduct inconsistent with an effective compliance and ethics program.

  • Appropriate background checks are performed on all new staff and those transferring positions.

5. The Institute provides training on compliance and ethics to all levels of the organization, including the governing authority.

  • Faculty and staff are trained on laws and regulations related to their positions, for example, FERPA regulations, payroll distribution confirmation, and safety. Institute management use various methods to deliver appropriate training, including presentations, administrative and academic forums, and web-based sessions to reach target audiences. Training programs are modified and delivered when there are changes in the regulations.

  • Compliance with federal, state, and local regulations and the Institute's ethical standards is stressed at new employee orientation.

  • The Deans and Division Chairs are updated periodically on compliance regulations and issues.

  • At the full Board meetings, the Trustees receive updates from the Audit and Compliance Committee on compliance matters.

  • At the new Trustee orientation program, new Trustees are informed of the Institute's Compliance Program and their related responsibilities.

6. Caltech uses auditing and monitoring systems to detect criminal conduct and ensure that employees and agents can report or seek guidance regarding ethical questions as well as potential or actual criminal conduct without fear of retaliation.

  • The Institute maintains a mechanism for employees and others to report workplace concerns, including suspected illegal and unethical behavior; non-compliance with laws, regulations, and policies; privacy issues; safety concerns; safety violations; criminal offenses, or other concerns. The Caltech Campus and JPL hotlines are available for callers to report serious concerns and violations to management in a confidential manner, without fear of retaliation. Callers may remain anonymous if they choose. The Institute Compliance Officer and the General Counsel are notified of all hotline contacts.

  • Information on accessing the Caltech Campus and JPL Hotlines is communicated across the Institute through brochures, websites, posters, and other means.

  • New employee orientation programs include Hotline information.

  • All Hotline complaints are monitored, responded to, and investigated. Hotline complaints are reported to senior management. General information on Hotline contacts is reported to the Audit and Compliance Committee annually. In addition, interim reports are provided to the Committee Chair on significant matters as they occur.

7. Caltech enforces compliance standards though disciplinary measures and incentives.

  • The Institute investigates allegations of misconduct timely and employees are disciplined, as appropriate, when misconduct has occurred. Disciplinary action taken may range from reprimands to administrative leave to termination, and may include referral for prosecution.

  • The Audit and Compliance Committee receives a report of investigations of fraud and the disciplinary action taken.

8. Caltech takes reasonable steps to respond to and prevent future similar criminal conduct.

  • In areas where fraud has occurred, the Institute works with relevant management to develop corrective action plans to prevent future occurrences.

Caltech’s Institute Compliance Program (ICP) is tailored after the United States Federal Sentencing Guidelines (FSG), Chapter Eight §8B2.1 “Effective Compliance and Ethics Program” that describes the elements for an effective compliance program.

Please see the following for additional information on the ICP:

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