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Policy & Procedure
Policy Title :
Reporting and Investigation of Potential Financial Misconduct Policy
Policy Number :
IV.A-18
Responsible Party :
Financial Affairs
Effective Date :
28/11/2013
Revised Date :
_______________________

Purpose

To protect the University and all its members from undue financial risks, this policy provides the guidelines to help everyone properly respond to situations that indicate financial misconduct.

Statement :
  • All members of the PMU community have a responsibility to ensure that University funds and resources are used only in activities that support the missions of the University; to protect University funds and resources from theft, misuse, misappropriation and other conduct that may be injurious to the financial welfare and reputation of the University; and to ensure the integrity of the University’s financial records through accurate reporting.
  • Financial misconduct refers to any intentional act to acquire financial gain for oneself or for those of relatives, friends, or associates from or through activities and transactions related to the business of PMU. Financial misconduct of any member of the University community results in material or financial detriment to the University. It may subject the University to serious consequences such as penalties, fines, disqualification from participation in international programs, debarment from research programs and withdrawal of various kinds of support from donors and agencies. Financial misconduct committed in any area of the University also poses harm to the reputation of the University as a whole and the University’s ability to advance its missions of education, research and public service.
  • To make sure that the University’s response to potential financial misconduct is consistent, effective and fair, all members of the University community are required to follow the procedures established in this policy on how activities believed to be financial misconduct should be reported and investigated. The University provides confidentiality and ethical conduct at all times.

Situations that Indicate Potential Financial Misconduct

All members of the University community have a responsibility to report known or suspected financial misconduct associated with the conduct of University business. Financial misconduct typically involves theft, forgery or embezzlement. Examples of financial misconduct include, but are not limited to:

  • alteration of records including financial reports, attendance and timekeeping reports;
  • submission of fraudulent business expenses for reimbursement;
  • acceptance of kickbacks from vendors;
  • overriding the University’s internal controls such as the established review and authorization processes for business expenses;
  • falsification or records related to financial transactions funded by external agencies (such as student loan providers and research funding sources);
  • falsification or alteration of various records related to accounting and financial reporting;
  • deliberate misrepresentation in financial reporting to University leadership and other recipients of financial reports, including donors, granting agencies and other governmental bodies.
Procedure :

Reporting Potential Financial Misconduct

  • When financial misconduct is suspected or uncovered by any member of the University community, it should be reported promptly and in a confidential manner. To report known or suspected financial misconduct, contact the Internal Financial Auditor of the University’s Office of Internal Financial Audit (OIFA), Extn 8548. Alternatively, you can also contact the University Secretary General, Extn 9262.
  • Heads of any department or unit of the University who receive reports of potential financial misconduct from any member of their staff are required to contact OIFA. All are advised to refrain from conducting an investigation on their own or from taking any action to resolve the irregularity before consulting OIFA.
  • All information regarding known or suspected of financial misconduct is deemed privileged and confidential. The University protects the identity of both those who alert the University to any irregularity and those suspected of wrongdoing.

Investigation of Potential Financial Misconduct

  • All reports of potential financial misconduct are promptly reviewed by the OIFA. The department’s auditor evaluates necessary records and information to verify the validity of the reports and to make a preliminary determination whether an investigation is warranted.
  • When an investigation is in process, all units of the University are required to respond promptly to OIFA inquiries and to provide access to relevant records.

Reporting Results

  • OIFA will prepare a report at the conclusion of the investigation that will summarize issues investigated, procedures followed, conclusions reached, and actions taken by administrative units of the University including the unit on which the investigation centered. The report will be provided to senior officers of the University, including the Rector and University Secretary General and General Counsel and the administrative or academic officers responsible for appropriate actions.

Disciplinary Action

  • The initiation of employee discipline, when warranted, is the responsibility of the College or Department. When disciplinary action is being considered, colleges and departments are advised to contact the University’s Human Resources Department to ensure compliance with University personnel policies. Human Resources must be informed of any disciplinary action being considered to also ensure that employee rights related to compensation and benefits are protected and harmonious employee relations are maintained.
  • Individuals who have been suspended from their post cannot be reassigned to their customary duties until the investigation has been completed and OIFA has released its recommendations.

Claims for Restitution

  • If the University has suffered a financial loss as the result of financial misconduct, the OIFA will provide a financial summary to the Office of General Counsel who will effect restitution.