V611.14 Reporting and Investigating Theft and Fraud

University employees are responsible for safeguarding University resources and ensuring they are used only for authorized purposes, in accordance with University rules, policies, and applicable law. All employees are responsible for reporting suspected theft, fraud, or unlawful or improper use of public funds or property.

A. As used in this policy, "theft, fraud or unlawful or improper use of public funds or property" includes:

stealing, larceny or embezzlement;
making or altering documents or files with the intent to defraud;
purposely inaccurate accounting or financial reporting at any level;
fraudulent conversion or misappropriation of public resources, including funds, supplies or other property;
improper handling or reporting of financial transactions;
authorizing or receiving compensation for goods not received, services not performed or hours not worked, including payment or receipt of a bribe, kickback or other unlawful or unauthorized payment.

B. Procedures for reporting suspected or detected fraudulent activity

An employee with knowledge or suspicion of theft, fraud or unlawful or improper use of public funds or property involving VCSU or affiliated entities, shall report that information to a supervisor, the Vice President for Business Affairs or the President. An employee with knowledge or suspicion of theft, fraud or unlawful use of public funds involving an immediate supervisor, shall report that information to an employee at a level above the immediate supervisor. As an alternate method, an employee may call the Eide Bailly Fraud Hotline at (866) 912-5378 to report suspicion activity.
Unreasonable failure to report such information as required may result in discipline, up to and including dismissal.
The employee or supervisor who suspects fraudulent activity should not attempt to conduct an investigation.
It is a violation of university policy to retaliate against an employee who, in good faith, reports dishonest or fraudulent activity.

C. Procedures for investigating suspected or detected fraudulent activity

The VCSU employees designated with responsibility for receiving and acting upon reports under this policy is the Vice President for Business Affairs (VPBA) and the Human Resources Director. A supervisor or other person who receives a report of suspected theft or fraud shall report that information to the VPBA or the Human Resources Director, unless the VPBA is implicated, in which case the information shall be reported to the President. The VPBA shall inform the President, unless the President is implicated, in which case the VPBA shall inform the General Counsel. If both the VPBA and the President are implicated, the report shall be made to the North Dakota University System General Counsel.
The VPBA shall take reasonable and appropriate action in response to receipt of a report, which may include an internal investigation, commission of an audit, referral to law enforcement officials, recommended policy or procedure amendments, a report summarizing findings or other steps. The VPBA shall consult the NDUS General Counsel and information shall be kept confidential as directed by the General Counsel.
The VPBA, with assistance from the Director of Human Resources as appropriate, has the primary responsibility for the investigation. If the investigation reveals that fraudulent activities have occurred, the VPBA will issue a report to the appropriate administrative officials.
Employee discipline, up to and including dismissal will follow University processes and procedures.
Decisions to prosecute or involve appropriate law enforcement and/or regulatory agencies for independent investigation will be made by the University President in consultation with NDUS General Counsel.
The VPBA is also responsible for periodic review of VCSU internal control procedures, making recommendations for appropriate controls and staff training to minimize opportunities for theft or fraud.

Sponsored by: Vice President for Business Affairs

Original: May 2007

Revised: August 2009

Revised: October 2009