Integrity and Compliance Office

The Integrity Thread: Weaving Compliance into VCU’s Culture with Suzanne Milton

When you hear the words “Integrity and Compliance,” you’ll likely think of a long set of rules, a “check-the-box” training or a ‘policing’ mindset.

 At VCU, we’re changing that narrative.

We recently sat down with our Chief Audit and Compliance Executive, Suzanne Milton, to discuss a major industry piece:The Principles and Practices of High Quality Ethics & Compliance Programs, a report from the Ethics & Compliance Initiative’s (ECI) 2016 Blue Ribbon Panel. The core message is simple: A great ethics program isn’t about just the rules—but a culture where integrity is a core part of our organization.

As a member of the Blue Ribbon Panel for this report, Suzanne emphasizes that ethics and integrity are a universal concept, regardless of the industry:

-Suzanne Milton, Chief Audit and Compliance Executive at VCU

“People will inevitably make mistakes,” says Suzanne. “The sign of a high-quality program isn’t just a scorecard for violations, it’s a set of habits and systems that help us learn and pivot from those moments.” Similar to brushing your teeth: it’s much easier to prevent a cavity today than it is to deal with a root canal later.

What is a High-Quality Program?
A High-Quality Ethics and Compliance Program, like VCU, goes beyond their organization’s required legal and regulatory expectations. These programs aim for a more profound purpose, keeping a high standard of ethics that becomes an integral part of the organization’s DNA. This report details the following principles that are foundational to a High-Quality Program.

Five Principles of a High-Quality Program (HQP)
Rules and regulations offer a helpful framework, but true integrity goes deeper. It’s about how we treat each other and the small, quiet choices we make in every moment. To foster this at VCU, we look at The Blue Ribbon Report’s five key pillars, turning ethics into a central part of our community:

1. Strategy: Ethics shouldn’t be an afterthought. It should be part of every big decision VCU makes. By participating in high-level strategic discussions, Integrity and Compliance ensures that every decision, from new initiatives to daily operations, is measured by its alignment with our core values.
2. Risk Management: Compliance isn’t just the responsibility of one office, everyone owns it. Every department and leader needs to look out for their own team and manage their own risks.
3. Culture: Leaders lead by example. When leaders act with integrity, it gives everyone else the opportunity to do the same.
4. Speaking Up: If you see something that doesn’t feel right, you should feel safe to say something. Suzanne Milton mentioned even a simple “thank you for telling me this” from a boss when someone reports a problem can make all the difference.
5. Accountability: The rules apply to everyone, regardless of title. If something goes wrong, we don’t just fix the mistake—we look at why it happened so we can prevent it next time.

The Impact of Integrity

The data is clear: When integrity is embedded into a program’s culture, they succeed. High-Quality Programs can reduce misconduct by as much as 66% and increase reporting to management by 88%. But beyond the numbers, it’s about strategic value.

“Instead of seeing compliance as a ‘police’ function, the report reframes it as a partner,” Milton explains. “This partnership ensures that VCU isn’t just following rules, but also building a culture of trust and collaboration.”

The Blue Ribbon Report is a living document meant to stand the test of time. At VCU, we want to go beyond the bare minimum, and make integrity a fundamental part of who we are –  empowering everyone to lead with honesty and heart.