Policies & Regulations
Fraud and Related Wrongful Acts
Major Revision of Existing Policy
Minor/Technical Revision of Existing Policy
Reaffirmation of Existing Policy
I. OBJECTIVE & PURPOSE
To further emphasize the importance of avoiding fraud as discussed in UNF's Code of Conduct and Ethics (1.0020P) the University has adopted this policy to specifically guard against fraudulent or other wrongful acts by the University's faculty and staff, to investigate indications of such, and prosecute or pursue disciplinary action in response to documented instances of violations of this policy.
II. STATEMENT OF POLICY
As a public university, the University's faculty and staff are accountable to the public and are often evaluated based on the public's perception of our stewardship. Further, the University's reputation and that of its employees may be damaged when fraudulent or other wrongful acts occur. For purposes of this policy, the definition of fraud and related wrongful acts encompasses an array of irregularities and illegal behavior, including but not limited to:
- Embezzlement, misappropriation or other financial irregularities,
- Forgery or alteration of documents (checks, time sheets, contractor agreements, purchase orders, other financial documents, electronic files),
- Improprieties in the handling or reporting of money or financial transactions,
- Misappropriation or misuse of funds, securities, supplies, inventory, or any other University property (including furniture, fixtures or equipment),
- Authorizing or receiving payment for goods not received or services not performed, and
- Authorizing or receiving payments for hours not worked.
Even the appearance of wrongdoing undermines the confidence and support that is critical for the University to achieve its mission.
UNF faculty and staff are to observe and comply with UNF's Code of Conduct and Ethics (1.0020P), the applicable provisions of the Code of Ethics for Public Officers and Employees, to the extent Part III of Chapter 112, Florida Statutes, applies and the terms of this policy against fraudulent and other wrongful acts. Administrators at all levels of management are expected to set the appropriate tone by displaying the proper attitude toward complying with laws, University regulations and policies and general ethical requirements. Administrators are responsible for establishing and maintaining proper internal controls which provide for the security and accountability of the resources entrusted to them. In addition, administrators should be cognizant of the risks and exposures inherent in their area of responsibility, and should be aware of the symptoms of fraudulent or other wrongful acts. In those instances where internal controls may need strengthening, the Office of Internal Auditing should be consulted for assistance on how to enhance those controls. In situations where there are questions regarding proper ethical behavior may arise, individuals should contact the University's Ethics Officer in the Office of the General Counsel.
III. STATEMENT OF PROCEDURES
A. Reporting Requirements
The UNF Board of Trustees and the President have designated the Office of Internal Auditing as the official contact for reporting suspected fraudulent or wrongful acts. Employees, with a reasonable basis for believing such acts have occurred, have a responsibility to report such beliefs to their supervisor, appropriate administrator or the Office of Internal Auditing. Faculty and staff shall not confront the individual being investigated, or initiate investigations on their own as such actions can compromise any ensuing investigation. Administrators, and all supervisory personnel, who become aware of suspected fraudulent or wrongful activity, are to respond in a consistent and appropriate manner by reporting the suspected activity to the Office of Internal Auditing who will then determine if an investigation is warranted.
This policy is intended to encourage the reporting of potential fraud or wrongful acts; therefore, individuals who report such conduct, and those cooperating with the ensuing investigation, are not to be subject to retaliation. If any reporting individual is concerned that they are suffering retaliation for reporting fraud and wrongful acts, they should immediately contact the Office of Internal Auditing or the Office of Human Resources to express their concerns. The University will make reasonable efforts to immediately address retaliatory behavior through investigating complaints of retaliation and disciplining those found to have engaged in retaliatory conduct.
If it is determined that an investigation is warranted, the Office of Internal Auditing is responsible for investigating the suspected fraudulent or wrongful act after consulting with the appropriate University representatives: Vice President and General Counsel, Vice President for Human Resources, University Police Chief, or other administrators as appropriate. During all aspects of any investigation, the legal rights of all persons are to be observed. The investigation will be completed expeditiously and in accordance with established procedures. All employees are to cooperate fully with those performing an investigation pursuant to this policy. All criminal investigations will be conducted in conjunction with campus police and/or the appropriate law enforcement agency.
D. Investigative Findings
The Office of Internal Auditing will report the results of any investigations, either orally or in writing, to the University President or other appropriate administrator.
Employees found to have participated in fraudulent or other wrongful acts will be subject to disciplinary action pursuant to collective bargaining agreements and University policies and regulations, up to and including termination of employment, and prosecution, if appropriate. In situations where disciplinary action is warranted, the University President, General Counsel, the Office of Human Resources, and/or other appropriate office will be consulted prior to taking such actions.
If you have any questions concerning this policy, please contact either the Office of Internal Auditing at (904) 620-2851, the Office of Human Resources at (904) 620-2903 or the Office of the General Counsel at (904) 620-2828.