Policy: 1.13 Fraud Responsibilities

Policy: 1.13 Fraud Responsibilities

Adoption Date: August 29, 2016

INTRODUCTION

Like all organizations, Howard College is faced with risks from wrongdoing, misconduct, dishonesty and fraud. As with all business exposures, we must be prepared to manage these risks and their potential impact in a professional manner. 

The impact of misconduct and dishonesty may include:

• the actual financial loss incurred,
• damage to the reputation of our college district and our employees,
• negative publicity,
• the cost of investigation,
• loss of employees,
• loss of customers,
• damaged relationships with our contractors and suppliers,
• litigation, and
• damaged employee morale.

Our goal is to establish and maintain a business environment of fairness, ethics and honesty for our employees, our students, our suppliers and anyone else with whom we have a relationship. To maintain such an environment requires the active assistance of every employee and supervisor every day. 

The college is committed to the deterrence, detection and correction of misconduct and dishonesty. The discovery, reporting and documentation of such acts provides a sound foundation for the protection of innocent parties, the taking of disciplinary action against offenders up to and including dismissal where appropriate, the referral to law enforcement agencies when warranted by the facts, and the recovery of assets.

PURPOSE

The purpose of this document is to communicate college policy regarding the deterrence and investigation of suspected misconduct and dishonesty by employees and others, and to provide specific instructions regarding appropriate action in case of suspected violations.

Definition of Misconduct and Dishonesty

For purposes of this policy, misconduct and dishonesty include but are not limited to:

• Acts which violate the college’s Guiding Principles and associated policies of the Employee Handbook;
• Theft or other misappropriation of assets, including assets of the college, our students, suppliers or others with whom we have a business relationship;
• Misstatements and other irregularities in college records, including the intentional misstatement of the results of operations;
• Profiteering as a result of insider knowledge of college activities;
• Disclosing confidential and proprietary information to outside parties;
• Forgery or other alteration of documents;
• Accepting or seeking anything of value from contractors, vendors, or other persons providing services/materials to the college;
• Fraud and other unlawful acts; and
• Any similar acts.

The college specifically prohibits these and any other illegal activities in the actions of its employees, supervisors, executives and others responsible for carrying out the college’s activities.

POLICY AND RESPONSIBILITIES

Reporting

It is the responsibility of every employee, supervisor and executive to immediately report suspected misconduct or dishonesty to their supervisor, the Chief Business Officer, or Human Resources.  Supervisors, when made aware of such potential acts by subordinates, must immediately report such acts.  Any reprisal against any employee or other reporting individual because that individual, in good faith, reported a violation is strictly forbidden.

Due to the important yet sensitive nature of the suspected violations, effective professional follow up is critical. Supervisors, while appropriately concerned about “getting to the bottom” of such issues, should not in any circumstance perform any investigative or other follow up steps on their own.  All relevant matters, including suspected but unproved matters, should be referred immediately to the respective cabinet member in order to insure proper incident handling.  If the cabinet member is in question, the employee should report the matter to the Chief Business Officer or President.

Additional Responsibilities of Supervisors

All employees have a responsibility to report suspected violations. 

However, employees with supervisory and review responsibilities at any level have additional deterrence and detection duties. Specifically, personnel with supervisory or review authority have three additional responsibilities.

First, you must become aware of what can go wrong in your area of authority.

Second, you must put into place and maintain effective monitoring, review and control procedures that will prevent acts of wrongdoing.

Third, you must put into place and maintain effective monitoring, review and control procedures that will detect acts of wrongdoing promptly should prevention efforts fail.

Authority to carry out these three additional responsibilities is often delegated to subordinates.  However, accountability for their effectiveness cannot be delegated and will remain with supervisors.

Assistance in effectively carrying out these responsibilities is available upon request through the Chief Business Officer/Internal Auditor. 

Questions or Clarifications Related to This Policy

All questions or other clarifications of this policy and its related responsibilities should be addressed to the Chief Business Officer, who shall be responsible for the administration, revision, interpretation, and application of this policy.