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Keeping it ethical: A Q&A with Rudy Green

Rudy Green, director of University Compliance Services, shares how his office works to keep the university ethical and compliant.

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Rudy Green is the director of University Compliance Services (UCS).

What is University Compliance Services’ role at the university?
Our office’s primary function is to make sure the university maintains a program that is effective in helping it avoid problems (and resulting costs) that arise out of compliance and ethics missteps.

How does your background in law complement your role with UCS?
I believe my 20-plus years of experience as an attorney, working in a heavily regulated industry, has helped me better understand the regulatory environment we operate in. Also, my training as a lawyer has allowed me to bring a research orientation to my position.

What has been the greatest transformation during your tenure at UCS?
I’d say a significant transformation occurred with the decision to hire me as a full-time director for the office and to have me report to the president, a decision that was obviously made before my arrival. This repositioning of the compliance function heightened the profile of our office.

After I arrived, I made a lot of effort trying to change the image of the office and to bring a stronger customer service orientation to the program. One of the significant changes was the decision to re-brand our effort by changing the name from the Office of Institutional Compliance to University Compliance Services.

Another transformational action we have taken has been to focus much of our effort on the promotion and support of an ethical culture here at UT rather than focusing exclusively on “legal” compliance. We believe the cultural environment greatly influences employees’ attitudes about compliance, and that a culture of integrity is not only important for preventing wrongdoing, but also important for employee happiness.

UCS is more than mandatory online compliance and ethics training. What are other key services of UCS?
There are three primary areas of service that we provide to the general community.

The first is training and education. You mentioned online training, but we also have the capacity to provide classroom training on a limited number of compliance and ethics topics.

We also provide compliance and ethics risk management services, typically for the benefit of management. Here we help managers understand their compliance and ethics risk environment.

Finally, we manage the university’s compliance and ethics hot line. This is a service employees can use to anonymously report wrongdoing within the university. The reports are received by a third-party service that takes the substance of the report and forwards it to our office.

An employee may also report wrongdoing directly to our office by phone, e-mail or in person. Of course, because we can identify the reporter in these instances, they are not anonymous.

What is a general misunderstanding employees have about UCS?
The biggest misunderstanding is that we are the “police” or are somehow here to make employees comply. Nothing can be further from the truth. In general, we do not have any direct authority over university personnel and expect to achieve our goals and objectives by the power of influence.

We actually see our main duty as making sure employees, especially management, have the training and tools to act accountably with respect to compliance and ethics matters, and that they in fact do act accountably.

What are a few keys ways UCS strives to keep UT an ethical place to work?
We believe people want to behave ethically. Our training program contains information aimed to improve employees’ ability to do the right thing by providing examples of potential ethical dilemmas.

For instance, conflicts of interest are a common ethical issue. Our training program, along with the Compliance and Ethics Guide, make employees aware of this issue and help them recognize a conflict of interest when it arises. By bringing this to their attention, we give them the tools to avoid making unintended unethical decisions.