Finance: Finance
Fraud & Financial Irregularities Policy

Approved by:	Board of Trustees
History:	Issued	--  March 14, 2002
	Revised	--  December 16, 2008
	Additional History
Related Policies:	Conflict of Interest
Additional References:	Financial Fraud Hotline and Reporting Procedures
Responsible Official:	Treasurer and Vice President for Finance and Administration  202-319-5606

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I.  Introduction

The university must safeguard its assets and protect its funds from thefts and misappropriations.  All members of the University community have a responsibility to report known or suspected financial irregularities.  Reporting of possible irregularities must be handled by all parties in a confidential manner. Financial irregularities may be criminal acts and subject to prosecution under the law. 

 

This policy applies to all faculty, staff and students.

 

II.  Definitions
N/A

III.  Guidelines and Regulations

When any member of the university community uncovers an instance of suspected or documented financial irregularity, it should be reported to the unit head who should then notify the Internal Auditor.  Alternatively, the individual may choose to go directly to the Internal Auditor [1].  If anonymity is preferred, the individual can contact the Hotline Phone Number, which is 202-319-4500.  Please review the Financial Fraud Hotline and Reporting Procedures, linked above, for more information.  The Internal Auditor has the responsibility for initiating any investigation into the matter if deemed appropriate. 

 

Department heads should take no action to resolve the irregularity before consulting the Internal Auditor.  The Internal Auditor will conduct the investigation to determine the validity of the charges.  The Internal Auditor and General Counsel may determine that additional investigation is required and shall have the authority after notification of the University President to consult with outside officials if appropriate.

 

Once the investigation is completed, the Internal Auditor will issue a report to the unit Vice President and the Treasurer and Vice President for Finance and Administration.  The unit Vice President is responsible for recommending and imposing university disciplinary action and will consult with the department head, as necessary.  Such action must be consistent with the Staff, Faculty or Student handbooks, as applicable.  The recommendation for discipline is to be made in consultation with the Internal Auditor and General Counsel. If the accused is a staff member, the Associate Vice President of Human Resources should also be consulted, if the accused is a faculty member, the Provost; and if the accused is a student, the Dean of Students. 

 

If the Internal Auditor should disagree with the recommended discipline, a committee including the department head, cognizant VP or Dean, the Associate Vice President of Human Resources, the Internal Auditor and the General Counsel, Provost (if the accused is a faculty member) or Dean of Students (if the accused is a student) will determine the discipline.  The General Counsel shall chair this committee.

 

Only the General Counsel may determine that a matter is to be referred to a law enforcement agency.  For any complaints that lead to investigation, the Internal Auditor shall be responsible for notifying the President, the Treasurer and Vice President for Finance and Administration, the University Risk Manager (the Associate Vice President for Business Services), the Chair of the Audit Committee of the Board, and as appropriate, Public Safety or Sponsored Programs, in consultation with General Counsel.