Fraud Reporting Policy

2.25

Purpose

The purpose of this Policy is to outline the appropriate reporting requirements of any known or suspected fraudulent activity involving employees, customers, vendors, contractors, consultants, or other parties related to the member institutions.

Definition

Fraud is defined as "Any illegal act characterized by deceit, concealment, or violation of trust. These acts are not dependent upon the threat of violence or physical force.  Frauds are perpetrated by parties and organizations to obtain money, property, or services; to avoid payment or loss of services; or to secure personal or business advantage." (Institute of Internal Auditors International Standards for the Professional Practice of Internal Auditing)

Examples of fraud include, but are not limited to:

  • Misappropriation of University property or other fiscal irregularities.
  • Forgery or inappropriate alteration of checks, drafts, promissory notes, or securities;
  • Forgery or inappropriate alteration of employee benefit or salary-related items such as time sheets, billings, claims, surrenders, assignments, or changes in beneficiary;
  • Forgery or inappropriate alteration of records relating to health;
  • Forgery or inappropriate alteration of student-related items such as grades, transcripts, loans, or fee/tuition documents;
  • Forgery or falsification of any official University document;
  • Misappropriation of funds, securities, supplies, or any other state asset;
  • Illegal or fraudulent handling or reporting of monetary transactions;
  • Acceptance or solicitation of any gift, favor, or services that might reasonably tend to influence the employee in the discharge of his or her official duties or that otherwise violates rules of the Oklahoma Ethics Commission;
  • Willful and unauthorized destruction of records, furniture, fixtures, or equipment.

Reporting

The OSU/A&M System is committed to ensuring the System operates in an ethical, honest and lawful manner.  Institutional administrators are responsible for preventing and detecting instances of fraud and related misconduct and for establishing and maintaining proper internal controls that provide security and accountability for the resources entrusted to them.  Administrators are also expected to recognize risks and exposures inherent in their area of responsibility and be aware of indications of fraud or related misconduct.

Individuals who have a reasonable basis for believing fraudulent activity has occurred should coordinate, as appropriate, with their immediate supervisor, department chair, dean and/or administrative head.   Individuals also have a duty to immediately report such incidents to the Office of Internal Audit (405) 744-6100 or through the Board of Regents EthicsPoint site.

https://secure.ethicspoint.com/domain/media/en/gui/10933/index.html

Anonymous reports through the EthicsPoint site must provide sufficient corroborating evidence to justify the commencement of an investigation.  While EthicsPoint is anonymous, individuals may choose to leave their name or contact information for the investigator to discretely contact the individual with additional questions. The OSU/A&M System has a Non-Retaliation Policy that requires the fair treatment of members of the OSU/A&M System who make good faith reports of potential violations of laws, regulation or policies. 

Reports and investigations of allegations of fraudulent activity ordinarily will be kept confidential to the reasonable extent possible under law and consistent with the need to conduct an adequate investigation and take corrective action.

Responsibility

The Office of Internal Audit has the responsibility to coordinate internal investigations of suspected fraud and will work with appropriate officials (e.g., the Office of Legal Counsel, Human Resources, institutional administration, law enforcement and/or departmental personnel) as needed. Institutional employees should not initiate their own investigations, since such actions may compromise ensuing investigations.     

Other References:

  • Board Policies
    • 1.09 Operations of the Office of Internal Audit
    • 3.05 Ethics
    • 3.06 Non-Retaliation
  • Charter for the Audit, Risk Management and Compliance Review Committee
  • Charter for the Office of Internal Audit
Approved Date: 
March 6, 2020