Purpose

To establish a PSU-wide compliance policy so that all PSU's stakeholders understand and commit themselves to the university’s obligations on compliance with internal policies, procedures and guidelines in addition to its compliance with its legal and contractual commitments and obligations.

Scope

The Compliance Policy applies to all PSU stakeholders as mentioned above. The policy will provide a uniform practical approach to ensure compliance with all policies and procedures, rules and regulations as approved by the Higher management of PSU.

This policy will ensure consistency in the PSU approach to compliance adhering to the principle of consistency between laws, by-laws, regulations and codes as put in PSU policies and procedures.

To uphold good regulatory compliance practice, the Policy is intended to be applied to matters relating to compliance with PSU policies and the applicable laws. It covers areas such as:

1. Governance and Administration
2. Quality Assurance
3. Teaching and Learning
4. Student Management
5. Research
6. Community Service
7. Information Technology Center
8. Central Library

Policy

The Senior Compliance and Legal Manager will nominate a Compliance Committee to manage and coordinate the PSU compliance program. The committee will comprise of individuals with the authority to execute these policies and procedures as well as individuals with the experience and the capability of monitoring and executing the compliance program. The committee members will be representatives of various departments of PSU and will be appointed for an academic year.

Composition of Compliance and Legal Office

1. The Compliance and Legal Office - Consists of the following members: A Senior Compliance and Legal Manager (Chair of the Compliance Committee) Administrative assistants (2) Legal Assistants (3) In-house Legal Counsel (1)
2. The Compliance Committee - Consists of six members (6)
3. Compliance College representatives - Consists of five members(5) representing the different colleges of PSU

Practice Standard

PSU’s Compliance Policy is based on the following best practice standards and principles:

• Compliance programs – PSU recognizes that there are four elements for an effective compliance program
• Commitment – PSU’s commitment to, and the establishment of, a compliance program
• Implementation – PSU’s implementation of a compliance program, including ongoing education and maintenance
• Monitoring and measuring – reporting and supervision of the compliance program
• Continual improvement – regular review and continual improvement of the compliance program

Responsibility: Senior Compliance and Legal Manager and Compliance Committee

• It will be the Senior Compliance and Legal Manager’s and the Compliance Committee’s responsibility to execute PSU’s compliance policy and plan.
• The Senior Compliance and Legal Manager and Committee will carry considerable weight and authority with the higher management, and great deference will be afforded to the Senior Compliance and Legal Manager’s and Committee’s recommendations.
• The Senior Compliance and Legal Manager will provide monthly updates to the president of PSU.
• The Senior Compliance and Legal Manager will have the responsibility for overseeing all efforts to manage and implement this compliance program.
• The Senior Compliance and Legal Manager and the Compliance Committee shall be open to discuss with all employees and other relevant stakeholders, report, or address any issues related to compliance.
• The Senior Compliance and Legal Manager is responsible for developing the system to solicit, evaluate, and respond to any compliance-related complaints or issues.
• All employees shall discuss concerns or other issues related to compliance with the Senior Compliance and Legal Manager directly without going through their direct manager/supervisor.
• Any other stakeholders are also encouraged to report any compliance-related issues to the Senior Compliance and Legal Manager.
• The Senior Compliance and Legal Manager will discuss the issue raised with relevant authorities to take an appropriate decision.
• All information discussed with the Senior Compliance and Legal Manager will be kept private and confidential.
• The Senior Compliance and Legal Manager will have significant authority and autonomy to address all compliance issues on a daily basis.
• The Senior Compliance and Legal Manager will be responsible for developing and distributing all compliance policies and procedures.
• All compliance reports will be reviewed and signed by the Senior Compliance and Legal Manager and then provided to the Compliance Committee.
• Any changes or developments in guidelines or issues will be monitored and incorporated on an ongoing basis by the Compliance Committee.
• The Senior Compliance and Legal Manager will be responsible for developing and maintaining the library of compliance-related materials, fraud alerts, and for distributing relevant information to keep the employees apprised of compliance-related issues.
• The Senior Compliance and Legal Manager and the Committee are responsible for monitoring and providing education to employees on compliance-related issues and processes.

Responsibilities of Others

• All administrators are considered to have the responsibility on a day-to-day basis to ensure that their staff in their respective areas practice proactive compliance management.
• As advised by PSU's Senior Management, all employees are responsible to familiarize themselves with the policies and procedures that apply to their responsibilities and ensuring compliance with relevant obligations.

Policy Administration

• The President of PSU approves this policy upon submission by the compliance and Legal manager upon recommendations of the Institutional Policy Committee.

Review

This policy and its related procedures will be reviewed on an annual basis and updated with any relevant changes. Any irregular revisions of the guidelines contained in this Policy must be appropriately reviewed and approved by the Senior Compliance and Legal Manager and in collaboration with the Compliance Committee and other managers.

Audit

• The Senior Compliance and Legal Manager and any of the committee members, may carry out a review of information and documents submitted by various departments and units and may request more information, upon the recommendation of the Senior Compliance Manager. Such requests must be met within the timeline provided.
• It is the responsibility of the Compliance Office to regularly audit administrative and academic documents and report back to the Senior Compliance and Legal Manager for actions needed.
• It is the responsibility of the Compliance and Legal Office to regularly conduct audits of salaries to ensure equity of pay between the two genders. Such requests must be met within the timeline provided.