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Fraud Deterrence

1. PURPOSE

This policy establishes the university’s position with respect to fraud; establishes the duty of university employees to report a suspicion of fraud as defined by this policy; provides protection from retaliation to those who, in good faith, report suspected fraudulent activity; defines consequences for fraudulent activity; and, outlines reporting processes and requirements.

As used in this policy, fraud is the intentional use of deceit or dishonest means to deprive the university of its money, property, or a legal right

2. POLICY

The university has adopted the Church Educational System (CES) Honor Code, which applies to all university-associated personnel (e.g., full and part-time faculty, administrative, staff, temporary, volunteer, etc.). All who represent the university are to maintain the highest standards of honor, integrity, morality, and consideration of others in personal and professional behavior. Fraudulent or unethical activity at the university constitutes a violation of the CES Honor Code and may subject the individual to disciplinary action up to and including termination of employment (see the Progressive Discipline Policy) as well as possible legal consequences.

Fraud deterrence at the university is the responsibility of all members of the campus community, particularly academic and administrative management. To effectively fulfill this charge requires the establishment of and adherence to effective policies, procedures, and internal controls. Periodic audits, systems reviews, and other special analyses can assist management in its responsibility. However, these aids should not be a substitute for the establishment and monitoring of effective controls that ensure the integrity of day-to-day university processes and operations.

Persons who cover up, obstruct the reporting of, or fail to report a fraud of which they are aware, may be subject to disciplinary action up to and including termination of employment as well as possible legal consequences.

3. IMPLEMENTATION


3.1 Duty to Report

All university personnel have a duty to report reasonable suspicions of fraud in the workplace to their direct supervisor, to the Chief Compliance Officer (5-3368), and/or through the university’s compliance reporting service, EthicsPoint, at 888-238-1062 or online at
https://secure.ethicspoint.com/domain/media/en/gui/17652/index.html.

Management and supervisors must promptly report all such concerns to the Chief Compliance Officer (5-3368). If, in consultation with the Office of the General Counsel and, if appropriate, the Vice President of Administration, the Chief Compliance Officer determines there is a reasonable basis for the allegation, he or she shall determine how to best proceed. The Chief Compliance Officer shall, when appropriate, also notify those with ultimate supervisory responsibility (e.g., Dean, Director, or equivalent manager) for the unit in which the alleged fraud occurred and/or the vice president of the university with responsibility for that unit. If the Chief Compliance Officer is the subject of a report of a reasonable suspicion of fraud, the university president, in consultation with the Office of the General Counsel, may designate an investigator. Nothing in this section (Duty to Report) should be understood to prevent university personnel from reporting reasonable suspicions of fraud in the workplace to their line managers.

3.2 Protection for Reporting

3.2.1 Confidentiality

The university shall keep confidential the identity of the person making a report under this policy except in the following circumstances:

  1. The person consents to disclosure voluntarily or a governmental agency compels disclosure (e.g., as per applicable law, lawfully issued subpoenas, warrants, court orders, or other investigatory documents issued by a court of competent jurisdiction); or,
  2. Maintaining such confidentiality would interfere with the conduct of an investigation of the specific allegations or with taking corrective action.

Confidentiality means disclosure will be made only to university employees or agents who have a legitimate need to know in order to perform their responsibilities to the university.

3.2.2 Retaliation

No adverse employment action may be taken against an individual for raising a concern in good faith under this policy. Additionally, adverse employment action may not be taken against a person for reporting a reasonable suspicion of fraud in the workplace to a government authority or who participates in a judicial, administrative, legislative, or university proceeding related to such allegations. Adverse employment action is broadly defined as any employment-related act or decision, including a failure to take appropriate action, by a supervisor or higher-level authority that might dissuade a reasonable employee from making or supporting an allegation of fraud in the workplace.

3.2.3 Violations

Violations of this section (Protections for Reporting) must be reported to the Chief Compliance Officer. Violations by the Chief Compliance Officer must be reported to the Human Resources Department or the Office of the General Counsel.

3.3 Sanctions

University employees who violate the terms of this policy may be subject to disciplinary action. Normally, involvement in fraudulent activities will result in termination of university employment, legal prosecution, and/or restitution. After considering all available information, the line vice president will recommend the disciplinary action to be taken. The President will make the final determination and approve all disciplinary actions. Legal consequences may occur independently of any university intervention.

4. RELATED POLICIES AND PROCEDURES

Progressive Discipline

Honor Code Policy

Details

Policy Owner: Chief Compliance Officer

Executive Sponsor: Administrative Vice President

Approved by President’s Council: 4/9/2018

Modified: 01/06/2020

Full revision history maintained by Human Resources.