Holmes & Associates has significant experience establishing, refining, and strengthening clients’ compliance and ethics programs, employee training, personnel practices, and corporate structure and governance. A well-designed and well-managed compliance program can help prevent situations that trigger a government investigation and mitigate consequences if one occurs. Holmes & Associates helps clients implement their internal compliance and ethics programs. We assist clients with issues relating to the formation and functions of board committees and assessments as part of ongoing compliance efforts. We also advise on the appropriate response to compliance issues as they arise.

Representative Matters

• Assisted client with the institutional response to sexual misconduct cases, providing consulting, counseling and legal advice on all issues related to sexual assault, intimate partner violence, stalking, and sexual and gender-based harassment.
• Provided compliance advice on handling Title IX proceedings on campus, including with regard to investigations, the campus judicial process, interim measures for complainants, due process and fundamental fairness for accused individuals, and disciplinary sanctions/remedies.
• Reviewed and assessed institutional programs to determine compliance with Title IX, VAWA, and related laws. Developed comprehensive sexual misconduct policies, procedures, systems, and training programs in compliance.
• Represented higher education institution involved in investigations by the U.S. Department of Education Office of Civil Rights and advised on achieving successful outcomes.
• Guided higher education institution through challenges associated with Clery Act compliance including advising on issues involving communications with law enforcement, Clery Act requirements, disciplinary proceedings, and federal and state requirements.
• Drafted Clery policies and procedures to ensure program compliance. Develop comprehensive security policies, procedures, systems, and training programs in Clery Act compliance.
• Reviewed annual security reports and annual fire safety reports and developed template documents for future submission of these annual reports to ensure compliance.
• Advised board of trustees on their role and responsibility in the higher education environment including their role in oversight for the institution’s federal regulatory compliance.
• Advised institutional management on effective risk management programs and policies.
• Created, revised, and implemented compliance programs, disciplinary codes, and policies on such topics as safety and security, sexual harassment, and drug and alcohol abuse.
• Drafted Drug Abuse and Alcohol Prevention Program (DAAPP) policies and procedures to ensure program compliance. Developed comprehensive policies, procedures, systems, and training programs in DAAPP compliance.
• Reviewed biennial review template for reporting the oversight of the DAAPP. Developed systems and methods for collecting campus information to evaluate the program, review publications, and produce the biennial review including recommendations for future action.

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