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,
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.
Examples of a fraudulent act include, but are not limited to:
Any dishonest act
Forgery or alteration of any document or account belonging to the
Forgery or alteration of a check, bank draft, or any other financial
Misappropriation of funds, supplies, or other assets
Impropriety in the handling or reporting of money or financial
Profiteering as a result of knowledge of College activities
Disclosure of confidential or proprietary information to outside
Acceptance or solicitation of anything of material value from vendors,
contractors, or consultants for personal gain
Destruction, removal, or inappropriate use of records, furniture,
fixtures, and equipment
Presenting a false claim
Making false information
Any similar or related inappropriate conduct
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.
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.
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.
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.
The reporting procedures for an employee who discovers or suspects
fraudulent activity are as follows:
Contact the College attorney immediately.
Share no information with any other person unless directed to do
so by the College attorney.
Do not contact the suspected individual in an effort to determine
facts, demand restitution, or otherwise.
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.