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I. Procedure Summary and Purpose
Worcester State University (WSU) promulgates this Fraud Policy to facilitate the development of controls which will aid in the detection and prevention of fraud, impropriety or irregularity within WSU. The University has a zero tolerance to fraud. It is the intent of the University to promote consistent organizational behavior by providing guidelines and assigning responsibility for the development of controls and conduct of investigations.
The University places a high level of trust in its faculty and staff, and requires that the University assets under their control be protected, used or legitimate univeristy business, and properly safeguarded from loss and misuse of assets including money, equipment and services provided by college personnel. The responsibility rests with all employees at all levels and throughout all departments.
Any investigative activity required will be conducted without regard to the suspected individual's length of service, position/title, or relationship with the University.
II. Policy Principles
Fraud - is defined as "an act of deceiving or misrepresenting in order to secure unfair or unlawful gain". Embezzlement is defined as "to appropriate (as property entrusted to one's care) fraudulently to one's own use".
Fraud takes many forms. Examples include misconduct such as untruthful financial reporting, expense report falsification, dishonest or false worker's compensation or insurance claims, kickbacks, bid rigging, and misuse of University checks, credit cards, computers, or services.
Fraud both undermines trust and depletes the University and the department involved of vital resources. Every member of the WSU community, regardless of his or her position is expected to cooperate and assist in preventing or identifying fraud.
III. Confidentiality and Whistleblower Protections-
Worcester State University faculty and staff are strongly encouraged to report a suspected case of fraud, theft, embezzlement, or misuse of University assets to your supervisor, chair and/or to the Director of either the Human Resource Office or the Office of the Vice President of Finance depending upon the nature of the violation
Chapter 149, Section 185 of the General Laws protects public employees who wish to make disclosures to expose violations of law or risk to public health, safety or environmental in a "whistleblower" mode.
The President, Vice-Presidents, Associate Vice-Presidents, Deans, Heads of Departments and area managers will treat all information received confidentially. Although University management prefers that sources identify themselves when reporting suspicion of fraud, anonymous fraud allegations will be accepted for consideration when supported by reasonable facts and circumstances. Such allegations should be mailed (mark envelope "Confidential") to the Director Of Human Resources Office in the Administration Building. The Office of the Inspector General Hotline (1-800-MISUSED) or (www.ed.gov/missused) is also available.
Disciplinary actions for proven violations of the policy, or for improper retaliaiton against anyone who reports possible violations, will be determined on a case-by-case basis and may include termination of employment. Those who violate this policy may also be subject to civil and criminal charges in some circumstances.
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