Procedure:

Reporting:

1. 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.
2. Unreasonable failure to report such information as required may result in discipline, up to and including dismissal.
3. The employee or supervisor who suspects fraudulent activity should not attempt to conduct an investigation.
4. It is a violation of university policy to retaliate against an employee who, in good faith, reports dishonest or fraudulent activity.

Investigating:

1. 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.
2. 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.
3. 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.
4. Employee discipline, up to and including dismissal will follow University processes and procedures.
5. 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.
6. 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.