Safeguarding University Resources
POLICY NUMBER: IAD-02
EFFECTIVE DATE: September 1, 2014
RESPONSIBLE OFFICER: Vice President, Internal Audit
To ensure protection of the resources of Drexel University and its affiliates (“University resources”) and to ensure that such resources are not misappropriated, misused, damaged, or destroyed; to provide a policy for the investigations of known or suspected misappropriation, misuse, damage/destruction and other irregularities concerning University resources; to determine the objectives of investigating suspected misappropriations and similar irregularities, to determine whether the suspected irregularity occurred, to ascertain the source and amount of funds involved, to identify the individuals responsible for the loss, to adequately document fraudulent activities, and to provide a sound basis for any subsequent corrective action.
It is the policy of the University to take prompt action to investigate all areas of (or expected areas of) fraud, and/or irregularities.
This Policy applies to Drexel University and its subsidiaries and affiliates (“University”), including all faculty and professional staff members of the University. University management at all levels of the organization are responsible for safeguarding financial and physical assets and for being alert to possible exposures, errors and irregularities. Management must be aware of internal control weaknesses which can lead to or permit misuse, misappropriation, or destruction of assets. This Policy regarding the safeguarding of resources and the investigation, processing, and reporting of suspected misappropriations and similar irregularities applies to all areas of the University.
For purposes of this Policy, the terms fraud, misappropriation, misuse, and other irregularities refer to, but are not limited to:
- Any dishonest or fraudulent act,
- Forgery or alteration of any document or account belonging to the University,
- Forgery or alteration of a check, bank draft, or any other financial document,
- Misappropriation of funds, securities, supplies, or other assets,
- Impropriety in the handling or reporting of money or financial transactions,
- Disclosing confidential and proprietary information to outside Parties,
- Accepting or seeking anything of material value from contractors, vendors or persons providing services/materials to the University, unless authorized pursuant to another University Policy. See Conflict of Interest and Commitment Policy – CPO-2 ; Acceptance of Personal Gifts Policy (CPO-5).
- Destruction, removal or inappropriate use of records, furniture, fixtures, and equipment; and/or any similar or related inappropriate conduct.
All faculty and professional staff, including those associated with a collective bargaining unit, are required under the Code of Conduct (CPO-1: Principle 7) to preserve and protect the University’s assets. This includes the obligation to report instances of suspected fraud, misappropriations or irregularities to the appropriate University officials. The University’s Office of Internal Audit is responsible for investigating actual and suspected fraud, misappropriation or irregularities. Internal Audit will work closely with and at the direction of the Office of the General Counsel, and with Public Safety and Human Resources when formally investigating such irregularities. When circumstances warrant, allegations may be referred to the Department of Public Safety or law enforcement agencies for investigation.
All supervisors and managers should be familiar with the types of irregularities involving misuse of University resources that might occur in their respective areas and be alert for symptoms that an impropriety is or was in existence in their respective areas. Any individual who detects or suspects a fraud, misappropriation or any irregularity shall notify his/her supervisor immediately. Reports can also be made anonymously to the University’s Hotline at 1-866-358-1010.
CPO-1 Code of Conduct Policy
The Vice President of Internal Audit has the primary responsibility for the investigation of all cases of misappropriation, fraud, reported irregularities and any other misuse of University resources. The Vice President is available and receptive to relevant information concerning suspected fraudulent activities on a confidential basis, to extent possible under the circumstances and in accordance with applicable law or regulations.
The Vice President of Internal Audit shall consult with, and coordinate the investigative activities with, other University offices as appropriate. All University faculty and professional staff shall cooperate fully with, and provide support to the Vice President as requested during such investigations and reviews. Failure to cooperate may result in disciplinary action, up to and including termination of employment.
Internal Audit will be given free, unlimited, and unrestricted access to all books, records, files, property, and to all personnel of the University during such investigations and as required by the Policy on Internal Audit (IAD – 01) . The Vice President, Internal Audit shall have the authority, after consultation with the Senior Vice President and General Counsel, and with the Provost when a member of the faculty is thought to be involved; and with other senior officials as appropriate to:
- take control of and/or gain full access to all University premises, whether owned or rented; and
- examine, copy, and/or remove all or any portion of the contents, physical or electronic, of all files, desks, cabinets, and other storage facilities which are located on such premises without the prior knowledge or consent of any individual who may use or have custody of such premises or contents. When an auditor removes any files or materials from desks or offices, and in order to protect the chain of custody, a record will be established and maintained. The record must be as complete as practicable; and a copy will be deposited with General Counsel and with the person or department from whose office the files or materials were removed.
OTHER INAPPROPRIATE CONDUCT
Other suspected improprieties concerning a faculty or professional staff member’s behavior or conduct, which is determined to fall outside this Policy, should be resolved by departmental management in consultation with the Department of Human Resources, or other appropriate departments, rather than Internal Audit. If there is any question as to whether an action of a faculty or professional staff member violates a University policy, or is inappropriate or improper, contact the Vice President, Internal Audit, Chief Compliance and Privacy Officer, or Office of the General Counsel, for guidance. In addition, such questions or matters can be directed to the University’s Hotline at:
866-358-1010 (toll free)
OED-1 Drexel Equality and Non-Discrimination Policy
OED-2 Reasonable Accommodation of Individuals with Disabilities Policy
OED-3 Sexual Harassment and Misconduct Policy
Reporting Discrimination, Harassment and Other Bias Incidents
CPO-1 Code of Conduct Policy
Great care must be taken in the investigation of suspected improprieties or wrongdoings so as to avoid mistaken accusations or alerting suspected individuals that an investigation is under way. Any faculty or professional staff member who discovers or suspects fraudulent activity will contact the Vice President of Internal Audit immediately. All inquiries concerning the activity under investigation from the suspected individual, his or her attorney or representative, or any other inquirer should be directed to the Office of the General Counsel. This Policy provides for confidentiality to extent possible under the circumstances and in accordance with applicable law or regulations, and confirms that any person who makes a good faith report of suspected improper conduct or who participates in the investigations of such a report will be protected from retaliation by the University or anyone within its control.
No information concerning the status of an investigation will be given out except to those employees who have a legitimate need to know in order to perform their duties. The proper response to any inquiries is: “I am not at liberty to discuss this matter.” Under no circumstances should any reference be made to “the allegation,” “the crime,” “the fraud,” “the forgery,” “the misappropriation,” or any other specific reference.
The reporting individual and other individuals cooperating with an investigation should be informed of the following:
- Do not contact the suspected individual in an effort to determine facts or demand restitution
- Do not discuss the case, facts, suspicions, or allegations with anyone unless specifically asked to do so by the Office of the General Counsel
The results of investigations by Internal Audit will be discussed with and issued to the Office of General Counsel and disclosed only to those who have a legitimate need to know such results in order to perform their duties.
After consultation with Office of the General Counsel, the Vice President of Internal Audit shall report the results of the investigation to the Senior Vice President for the area under review and to the Provost, if a member of the faculty is determined to be involved. All cases of fraud, misappropriation and irregularities under investigation shall be reported to the President, and subsequently to the Audit Committee as stated in the Audit Committee Charter.