Procedures to follow when a suspicion or discovery of financial irregularities arise. Some common types of financial irregularities are corruption (e.g., bribery, kickbacks, bid riggings, etc.), conflicts of interest (e.g., sale and purchase schemes, etc.) and asset misappropriation involving cash, inventory or other University assets. Examples of asset misappropriation can include the following:
- theft of cash
- the use of a University issued credit card or the expense reimbursement system to make personal purchases
- the directing of University resources such as supplies, inventory or labor to outside organizations
- the directing of University revenues (e.g., event ticket proceeds, research funding, etc.) to outside organizations
Departments must immediately notify the Office of the Chief Risk Officer or the Compliance and Ethics Helpline of suspected financial irregularities. Departments should not initiate an investigation. Departments should not discuss, interview or confront individuals about the suspected financial irregularity. Departments should not initiate any disciplinary actions without specific direction from the Office of General Counsel, or the Office of the Chief Risk Officer.