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134.00 REPORTING OF FRAUD

This policy outlines the methods employed for reporting and investigation of suspected or actual fraudulent acts against Cowley County Community College by any person, officer, employee, vendor, contractor, consultant, or agent.

  1. Fraud is defined as the intentional, false representation or concealment of a material fact for the purpose of inducing another to act upon it to his or her loss or damage.
  2. Examples of a fraudulent act include, but are not limited to:
    1. Any dishonest act
    2. Forgery or alteration of any document or account belonging to the College
    3. Forgery or alteration of a check, bank draft, or any other financial document
    4. Misappropriation of funds, supplies, or other assets
    5. Impropriety in the handling or reporting of money or financial transactions
    6. Profiteering as a result of knowledge of College activities
    7. Disclosure of confidential or proprietary information to outside parties
    8. Acceptance or solicitation of anything of material value from vendors, contractors, or consultants for personal gain
    9. Destruction, removal, or inappropriate use of records, furniture, fixtures, and equipment
    10. Presenting a false claim
    11. Identity theft
    12. Identity fraud
    13. Making false information
    14. Any similar or related inappropriate conduct
  3. The College attorney has the primary responsibility for the investigation of all suspected fraudulent acts as defined in this policy.  If the investigation substantiates that fraudulent activities have occurred, the College attorney will issue a report to the President, who may delegate or reprimand as appropriate. 
  4. Decisions to terminate, prosecute, or refer to the appropriate law enforcement and/or regulatory agencies will be made by appropriate administrative staff in consultation with the College attorney.
  5. The College attorney will treat all witness statements, reports, and other information received confidentially.  Investigations and the results thereof will not be disclosed or discussed with anyone other than those who have a legitimate need to know.  The same shall not constitute an open record.
  6. The College attorney will have access to all College records necessary, including the ability to remove certain records or equipment to a neutral site if appropriate.
  7. The reporting procedures for an employee who discovers or suspects fraudulent activity are as follows:
    1. Contact the College attorney immediately. 
    2. Share no information with any other person unless directed to do so by the College attorney.
    3. Do not contact the suspected individual in an effort to determine facts, demand restitution, or otherwise.
  8. If an investigation results in a recommendation to terminate an employee, the recommendation will be reviewed by Employee Services for documentation.
Cowley College will not retaliate against an employee who, acting in good faith, reports suspected or actual fraud through the process outlined in this policy.  Retaliation includes demotion, termination, denial of benefits, failure to promote, intimidation, reassignment, or other discriminatory actions that would negatively impact the terms and conditions of the reporting employee’s employment, or dissuade a reasonable person from making reports under this policy in the future.

 

 

 

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