What is Fraud?
Fraud generally involves a willful or deliberate act with the intention of obtaining an unauthorized benefit, such as money or property, by deception or other unethical means.
The Institute of Internal Auditors characterizes fraud as “an array of irregularities or illegal acts characterized by intentional deception. It can be perpetuated for the benefit of or to the detriment of the organization and by persons outside as well as inside the organization.”
Such acts include but are not limited to:
- Purchasing personal items with a university purchasing card
- Forgery, falsification, or alteration of documents
- Misappropriation of funds, securities, supplies, inventory, or any other asset
- Intentional misrepresentation of events or data
- Authorizing or receiving payment for hours not worked
- Authorizing or receiving payment for goods not received or services not performed
- Improprieties in the handling or reporting of money or financial transactions
- Acceptance of bribes or kickbacks
- Bloating expense reports
- Stealing Intellectual Property
- Using equipment or resources for private or personal purpose
Case Western Reserve University’s mission of excellence in education, research, and clinical service depends on the integrity of all members of its community – employees, retirees, vendors, students, and alumni. This Hotline Policy is being established to communicate the methods for members of the university community to report unethical or illegal behavior that might jeopardize the university’s mission and the procedures to be followed for investigating those reports.
This fraud policy describes an additional resource for the university community and is not intended to alter or replace existing university policies.
A non-exhaustive list of unethical or illegal behavior might include:
- Shortcomings in regulatory compliance
- Theft of university assets or use of such assets for personal benefit
- Inappropriate relationships with employees, customers, or vendors
- Excessive gift(s) from a vendor
- Sexual harassment of or discrimination against an employee or student
- Falsification of timesheets or university records
- Scientific misconduct
- Information Security Breach
- Misuse of sponsored research funds
- Bribes or kickbacks
- Purchase of personal items with university funds
- Improper financial reporting
- Questionable accounting/auditing
Filing a Fraud Report
All members of the university community have a duty to report unethical and illegal conduct at the university. Individuals are encouraged to first report their concerns to their supervisor (if an employee) or to another appropriate university official. However, if that is not deemed a viable option, or if the individual believes his or her concerns are being ignored, he/she can report any concerns to such university offices as Internal Audit Services, Employee Relations, Equal Opportunity, and Diversity, Protective Services, Office of General Counsel, or Research Compliance. Direct reports to a university supervisor or office help us gather information and determine the overall scope and nature of the alleged misconduct.
Initial reports to the hotline call center are submitted to an appropriate university contact for follow-up. These contacts made may include managers from the offices listed above.
Employees who report conduct that they believe is illegal or unethical should have a reasonable factual basis for believing that improper activities have occurred, and should include as much specific information as possible to allow for proper assessment of the nature, extent, and urgency of the incident.
The university will review every report to the hotline. An investigation will be conducted if a review establishes that the allegation constitutes unethical or illegal activity and if it is supported by specific information or corroborating evidence. Departments within the university that have responsibility for conducting investigations include Internal Audit Services, Employee Relations, Equal Opportunity, and Diversity, Research Compliance, Office of General Counsel, and Protective Services. Other departments may become involved in investigations based on their areas of oversight responsibility or expertise.
Efforts will be made to perform investigations discreetly. The details of the investigation will be kept confidential, to the extent feasible, and consistent with university policies and applicable federal, state, and local laws.
Protection and Responsibilities
University employees are prohibited from retaliation against, or any form of harassment of, an individual who reports a concern in good faith. Any employee who engages in retaliation or harassment against a reporter is subject to discipline, up to and including termination. All reported concerns are presumed to be in good faith unless established otherwise. Knowingly false allegations are prohibited.
The university is committed to conducting an appropriate and timely response to each report submitted through the hotline, as well as appropriate and timely closure to those allegations which proceed to the investigation process.