Reporting Fraud or Misappropriation

I. Reporting Fraud

All university community members are encouraged to report possible fraudulent or related misconduct. Any individual suspected of fraud or related misconduct should not be confronted. Employees should report their concern(s) through normal management reporting channels, beginning with their immediate supervisor. Upon notification of the suspected fraud or misconduct, the supervisor is required to report the instance to the Internal Audit Department (IAD). An employee can report their concerns directly to the Internal Audit Department if they find it difficult to discuss/report with their supervisor or the suspected fraud involves the supervisor.

Reporting potential fraud or misuse of university resources to the IAD can be made confidentially or anonymously. The Internal Audit Department cannot guarantee the whistleblower’s confidentially; however, IAD will keep the whistleblower's identity confidential, unless (1) the person agrees to be identified, (2) identification is necessary to allow the university police to investigate or respond effectively, (3) identification is required by law; or (4) the person accused of fraud or misconduct is entitled to the information as a matter of legal right in disciplinary proceedings.

Anonymous whistleblowers must provide sufficient corroborating evidence to justify the commencement of an investigation. An investigation of unspecified wrongdoing or broad allegations will not be undertaken without verifiable evidentiary support. Since the IAD cannot interview anonymous whistleblowers, evaluating the allegation’s credibility may be difficult and; therefore, less likely to initiate an investigation.

The university views exposing fraud or misconduct as a service, and consistent with the State of Michigan's Whistleblowers’ Protection Act, will not jeopardize employment. To encourage the reporting of improper governmental actions, employees are protected from retaliation by the provisions of state law.

II. Investigative Responsibility

The university will investigate any reported fraudulent or misuse of university resources or property by faculty, staff or students. The Internal Audit Department is responsible for conducting investigations of all alleged fraudulent or dishonest conduct. University employees should not initiate their own investigations, since such actions may compromise ensuing investigations. IAD shall promptly notify the university president of the reported allegation(s) and consult with other university officials deemed necessary or appropriate. Cases involving possible criminal law violations will be turned over to the university police for investigation. If requested, IAD will provide assistance on university police investigations.

The Internal Audit Department’s investigation results will only be disclosed to university employees having a legitimate need to know in order to perform their job duties and responsibilities. If IAD determines that fraudulent or dishonest conduct occurred, the appropriate university official(s) will initiate disciplinary action in a manner consistent with applicable university policy.

If IAD concludes the allegations were unsubstantiated, IAD will provide the whistleblower, if known, an explanation justifying its determination.

III. Definitions

Fraud
The willful or deliberate act or failure to act with the intention to deceive or obtain an unauthorized benefit. Such acts include, but are not limited to:

• misappropriation or misuse of university resources
• intentionally reporting inaccurate financial results
• making or altering documents or computer files with the intent to defraud
• pursuit of a benefit or advantage in violation of the university's conflict of interest policy
• authorizing or receiving compensation for goods not received or services not performed
• authorizing or receiving compensation for hours not worked
• destruction or disappearance of records, furniture, fixtures or equipment
• any similar or related irregularity

Whistleblower
A person making a protected disclosure regarding an activity they believe is fraudulent or dishonest. Whistleblowers may be university employees, students, vendors, contractors or the general public. The whistleblower’s role is as a reporting party. They are not investigators or fact finders, nor do they determine the appropriate corrective or remedial action that may be warranted.

IV. Non-Fraud Irregularities

Identification or allegations of personal improprieties or irregularities, whether moral, ethical, or behavioral, should first be resolved by the supervisor in the respective department in coordination with University Human Resources. The Internal Audit Department may be contacted if guidance is needed to determine if an action constitutes fraud.

Allegations of student misconduct should be addressed to the Dean of Students for investigation.