| Policy Title | Fraud and Irregularities / Compliance Hotline Policy |
|---|---|
| Responsible Office | Risk Management and Administrative Compliance |
| Policy Type | Personnel and Payroll |
| Policy Number | 631 |
| Last Revision Date | 8/15/2023 |
Summary
ºÚÁÏÊÓƵ is committed to upholding the highest standard of honest behavior, ethical conduct, and fiduciary responsibility with respect to campus funds, resources, and property. As such, the University seeks to prevent and detect any fraud or irregularities and will diligently pursue any instance that involves University-related activities or business.
Policy
It is the policy of ºÚÁÏÊÓƵ that all members of the campus community:
- comply with all campus and SUNY policies and procedures; New York State and federal laws, and regulations;
- practice honesty and integrity in fulfilling their responsibilities;
- observe high standards of business and personal ethics in the conduct of their duties and responsibilities;
- help ensure the prevention and detection of fraud and irregularities;
- be familiar with the types of fraud and irregularities that might occur in their area;
- be alert for any indication that fraud or irregularities might exist in their area; and
- promptly report any known or suspected fraud or irregularities involving campus or affiliated entity funds, resources, property, or employees.
It is University policy that employees and individuals who lawfully report suspected fraud, waste, or abuse shall not suffer discharge, demotion, suspension, threats, harassment, discrimination, or other forms of retaliation for making such reports in good faith.
If an individual believes that they have been retaliated against for reporting a compliance concern or for participating in a compliance investigation, that individual should follow the guidelines outlined in our Non-Retaliation policy.
Breaches of our campus Non-Retaliation policy may result in disciplinary action, up to and including, termination of employment.
Overview and Contact Information
The Fraud and Irregularities/Compliance Hotline (607-777-5049) is a support process within our organizational compliance program. For the purpose of this hotline, fraud and irregularities includes activities that are (1) a misappropriation of assets; (2) in violation of or non-compliant with any SUNY, New York State, or federal law, regulation, policy or procedure; (3) economically wasteful; (4) an indication of gross misconduct or incompetency; or (5) an unethical, improper, or dishonest act. Examples of improprieties include, but are not limited to, the following:
- Theft of any State or SUNY asset including, but not limited to money, tangible property, trade secrets or intellectual property;
- Misappropriation, misapplication, destruction, removal, or concealment of State or SUNY property;
- Inappropriate use of computer systems, including hacking and software piracy;
- Unauthorized disclosure of confidential or proprietary information;
- Unauthorized disclosure of student educational records, personal information, or medical information;
- Authorizing or receiving compensation for hours not worked or covered by appropriate and available leave;
- Fraudulent or otherwise deceptive financial reporting;
- Credit card and travel expense fraud;
- Use of staff to perform personal errands, services or tasks;
- Alteration or falsification of documents;
- False claims by students, employees, vendors or others associated with SUNY; and
- Bribery, kickbacks, bid rigging and conflicts of interest.
Activities described above that may constitute fraud or irregularities may also be covered by existing policies and procedures on specialized topics. Such activities may still be reported under this policy, but will be referred for handling to the extent such other procedures exist. Examples of such policies include:
- Individual employee grievances and complaints concerning terms and conditions of employment will continue to be reviewed in accordance with applicable academic and human resources policies and collective bargaining agreements.
- Complaints regarding sexual harassment and unlawful discrimination on the basis of race, color, national origin, religion, age, sex, sexual orientation, disability, veteran or marital status should be reported to the designated officer and handled in accordance with the applicable complaint procedures.
- Student academic grievances should follow local campus policies and procedures.
- Complaints regarding research administration are generally the responsibility of the Research Foundation for SUNY.
- Complaints related to construction projects administered by the State University of Construction Fund (SUCF) or the Dormitory Authority of the State of New York (DASNY) are generally the responsibilities of those entities.
- Complaints related to a SUNY community college should be filed with the appropriate community college.
If you need help finding a University policy, you should contact the University Ombudsman.
Employees are encouraged to speak first with their supervisor or with a University official who has oversight for the area in question. If that is not a comfortable, possible or appropriate option — contact the Fraud and Irregularities / Compliance Hotline.
All calls are taken seriously and will be investigated by the appropriate University office. Whenever possible, the resolution of any investigation will be conveyed to the caller.
Confidentiality and Anonymity
Upon request, every attempt will be made to maintain the confidentiality of individual callers to the Fraud and Irregularities / Compliance Hotline. However, in some situations this may prohibit the effectiveness of an investigation, and for this reason, cannot be guaranteed.
Although it may be used anonymously, the Fraud and Irregularities / Compliance Hotline is most effective when communication is open and when the availability exists to clarify and to follow up on reported concerns.
If a caller elects to proceed anonymously, the importance of that caller providing sufficient detail cannot be overemphasized.
Alternate Resources
There may be instances when an individual would prefer to discuss or clarify a work-related situation, before, or in place of, contacting the office or Risk Management and Administrative Compliance. With this in mind, know that there are alternate resources available on campus and off for potential compliance issues.
- Ethics Officer (607-777-2187)
- University Ombudsman (607-777-2388)
- Human Resources (607-777-2187)
- Internal Audit (607-777-2128)
- SUNY System Administration - University Auditor (518-320-1539)