The Catholic University of America

Finance: Finance
Reporting Financial Irregularities Policy

Approved by: Board of Trustees
History: Issued                         -- March 14, 2002
  Revised                       -- September 20, 2012
Related Policies: Conflict of Interest Policy for Staff and Faculty; Reporting Ethical Misconduct and Non-Retaliation Policy
Additional References:

Compliance and Ethics Helpline tel. (855) 350-9396, www.thecatholicuniversityofamerica.ethicspoint.com

Responsible Official: Vice President for Finance and Treasurer tel. (202) 319-5606

__________________________________________________________________________________

I.     Introduction

All instances of suspected financial irregularities must be reported immediately to the Vice President for Finance and Treasurer who is responsible for coordinating review and any investigation of the suspected irregularity. Alternatively, individuals may report suspected irregularities anonymously through the Compliance and Ethics Helpline at tel. (855) 350-9396 or online at www.thecatholicuniversityofamerica.ethicspoint.com. Pursuant to the University’s Reporting Ethical Misconduct and Non-Retaliation Policy, retaliation against individuals for making good faith reports is strictly prohibited, and is subject to disciplinary action up to and including termination.

II.     Definitions

Financial Irregularities include theft or misappropriation of funds, supplies, property, or other resources; misreporting hours worked; fraud or deliberate errors in the preparation, evaluation, review or audit of any financial statement of the University; forgery or alteration of University financial documents or financial computer files; pursuit of a financial benefit or advantage in violation of the University’s conflict of interest policies; or deficiencies in or noncompliance with the University’s financial controls.

III.     Reporting Financial Irregularities

Members of the university community who discover instances of suspected financial irregularities immediately must report such instances to the Vice President for Finance and Treasurer (VPF&T) at (202) 319-5606.  Alternatively, individuals may report suspected irregularities anonymously through the Compliance and Ethics Helpline at tel. (855) 350-9396 or online at www.thecatholicuniversityofamerica.ethicspoint.com.  The Compliance and Privacy Officer, who administers the Helpline, shall forward all such reports to the VPF&T. Individuals should take no action to resolve the suspected irregularity before consulting the VPF&T. 

IV.     Reviewing and Investigating Financial Irregularities

The VPF&T is responsible for reviewing all reports of suspected financial irregularities and coordinating any investigation as necessary.  The VPF&T shall have the authority, after notification to the University President and the General Counsel, to consult with outside officials in the course of or pursuant to an investigation, as deemed appropriate.  However, 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 VPF&T shall be responsible for notifying the President, the University Risk Manager, the Chair of the Audit Committee of the Board, and any internal or external auditors, as necessary.