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Fraud and Fraudulent Activities
All employees of the
Texas Woman's University have a responsibility to report fraud or
suspected fraud. Fraud encompasses an array of irregularities and illegal
acts characterized by intentional deception. These include (but are not
limited to) theft, embezzlement, bribery, misappropriation, kickbacks,
destruction or removal of property, and conflicts of interest.
At TWU, the Chancellor and the Vice
Presidents have the primary responsibility for identifying potential
areas of risk and for being aware of the possibility that fraudulent acts
could occur in those areas. Information detailing the risk areas and how
to detect and prevent fraudulent activities are available from the TWU
Internal Audit Department. The officers of the University shall notify
all TWU employees that they are to report incidents of fraud or suspected
fraud in accordance with procedures outlined in this fraud policy.
When fraudulent incidents or
practices are observed by or made known to an employee, the following
procedures must be followed.
- The
incident or practice shall be reported to the Internal Audit
Department or the Department of Public Safety. The departments shall
work together and, based upon the type of incident, determine who
will have the primary responsibility for the investigation,
documentation, and reporting of the incident except as otherwise
authorized by the Chancellor or Board of Regents. All such
investigations, documents, and reports shall be considered
confidential and highly security-sensitive to the extent allowable
by the law.
- The
reporting employee shall refrain from further investigation of the
incident, confrontation of the alleged violator, or further
discussion of the incident with anyone other than the internal
auditor and/or law enforcement personnel, but shall cooperate in
their investigative process. TWU officials will not allow
retribution against individuals providing information concerning
fraud or suspected fraud for acting in the best interest of the
institution.
- The
investigating department will notify the Vice President for Finance
and Administration of the incident as soon as the validation of
allegation is determined. Full cooperation between the internal
audit function and the law enforcement function is necessary for
full utilization of resources available for the safeguarding of
assets.
- The
Internal Audit Department shall consult with the Office of General
Counsel as necessary so that appropriate legal measures are taken
during the investigation to protect the rights, privileges, and
responsibilities of all parties involved.
- The
campus police shall prepare a case report for each investigation
where there is authenticated evidence present to show that fraud has
been committed as defined by this policy. Each case report shall
include (but not be limited to) the following: subject of the
investigation; statement of non-compliance with policy, plan,
procedure, law, or regulation; description of acts or practices
discovered; statements of witnesses; appropriate documentation; and
other data considered necessary by law enforcement officials.
- The
Internal Audit Director shall prepare a report giving the amount and
type of loss, the means used to perpetrate the fraud, and action to
be taken to reduce additional losses. The report shall be
distributed to the Chancellor, Vice President for Finance and
Administration, and other administrators as necessary. A summary
report shall be presented to the Finance and Audit Committee of the
Board of Regents.
- The
Chancellor will direct the actions to be taken unless otherwise
delegated to other administrators. Remedies include (but are not
limited to) termination of employment, restitution, and forwarding
information to the appropriate authorities for criminal prosecution.
APPROVED: 3/94
REV: 9/08
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