Fraud, Waste, Theft, and Abuse Policy

Purpose: To prevent and detect fraud, waste, theft, and abuse. To assign responsibility for implementing appropriate internal controls to prevent, deter, and detect fraud, waste, theft, and abuse. To establish the appropriate reporting mechanisms to be used for notification of known or suspected fraud, waste, theft, and abuse. To establish the consequences for fraud, waste, theft, and abuse by employees.

Applies to: All Pittsburg State University employees, customers, vendors, contractors, consultants, or other parties related to the University.

Policy:

Pittsburg State University is committed to conducting its affairs ethically and in accordance with applicable laws, rules, regulations, policies, and procedures. Each member of the PSU community is expected to share in this responsibility. As a publicly supported institution, PSU has a fiduciary responsibility to conserve, preserve, and efficiently use all University resources and property. PSU is committed to establishing and maintaining strong internal control systems to assist in the prevention, deterrence, and detection of fraud, waste, theft, and abuse.

Leadership

Administrators with supervisory responsibility at all levels within PSU, are responsible for establishing the appropriate tone of intolerance for fraud, waste, theft, and abuse by establishing a culture founded on integrity and high ethical standards and principles. Each administrator is responsible for the adequacy of financial and other internal controls within her/his area of responsibility. This responsibility requires acting prudently and inquisitively while being aware of activities and locations where violations of this policy are likely to occur.

Reporting

Employees and other individuals associated with PSU who become aware of, or have a reasonable basis for believing that fraud, waste, theft, or abuse has occurred shall promptly report the suspected activity to either Internal Audit or University Police and Public Safety. Reports can also be made online through PSU’s Compliance and Ethics Hotline or by phone at 844-410-0003. Both are anonymous and available 24 hours a day, 365 days a year.

Any employee who has knowledge of fraud, waste, theft, or abuse of University assets by any person or organization, including another employee, and does not report it to University officials may be subject to disciplinary action, up to and including termination of employment.

It is not necessary to have proof of wrongdoing at the time of reporting suspected violations of this policy; however, anyone reporting such activity should have reasonable grounds for doing so. No disciplinary or retaliatory action shall be taken against any PSU employee who, in good faith, reports or causes to be reported suspected fraud, waste, theft, or abuse or who assists in an authorized review of alleged fraud, waste, theft, or abuse.  An adverse action toward an individual may be reported on line through PSU’s Compliance and Ethics Hotline or by phone at 844-410-0003.

The prohibition against disciplinary action does not extend to disciplinary action for self-reported violations.

Investigation of Reports

University Police and Public Safety shall investigate allegations of fraud and theft in accordance with established University policies and procedures.

Internal Audit shall be responsible for ascertaining the extent of loss and for reviewing and evaluating control and/or process failures related to the loss. Internal Audit will notify the University President, the Vice President of Business, Finance and Facilities and the General Counsel.

CONSEQUENCES

PSU employees engaging in fraud, waste, theft, or abuse, as defined by this policy may be subject to disciplinary action. PSU employees suspected of perpetrating fraud, waste, theft, or abuse may be placed on administrative leave during the course of the investigation. If the violation is identified as a crime, it will be reported to the appropriate law enforcement organization. Criminal investigations will be conducted separately from any internal investigation. Information obtained by the internal investigation will be made available to law enforcement to assist in the criminal investigation.