4.72 Reporting Potential Fraud, Damage, or Theft of College Property

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I. Purpose

Central Piedmont Community College intends  to comply with the NC General Statute 143B-920 and the State Board of Community Colleges Code 1H SBCCC 200.86 (6) Withholding of State Funds or Administrative Support regarding reporting information or evidence of arson, theft, damage, embezzlement, or misuse of state property to the State Bureau of Investigation.

II. Rule

In order to ensure compliance with statutory provisions and state regulations, employees must report information or evidence of possible fraudulent or corrupt activity, and they must cooperate with investigations initiated under these regulations. Additional information on reporting possible violations involving the misuse of state property can be found at NC General Statute 143B-920 and 1H SBCCC 200.86 (6).

III. Definition

Fraud covers a number of illegal acts including intentional deception, theft, embezzlement, false representation, concealment, misappropriation of resources, manipulation of data, identity theft, and other inappropriate conduct.

IV. Procedures

A. Any employee who has or receives information or evidence of an attempted arson, or arson, damage of, theft from, or theft of, or embezzlement from, or embezzlement of, or misuse of any state-owned, college-owned, grant-funded, donated, or loaned personal property, buildings, or other real property must report this information or evidence as soon as possible, but not later than three days from its receipt, to his/her immediate supervisor and CPCC Security. Failure to report information or evidence within this three-day time period may result in disciplinary action.

B. The reporting employee (or his/her immediate supervisor) must contact CPCC Security, who will complete an Automated Records Management System (ARMS) Incident Report. Security will notify Internal Audit immediately for incidents involving potential financial irregularities, misappropriation of funds, or embezzlement.

C. In the event that any person with a reporting obligation under this policy believes that there is a conflict of interest on the part of the person to whom the allegations of suspected improper activities are to be reported, the next higher level of authority shall receive the report.

D. Upon notification of the incident, Security will:

1. Advise the Vice President for Finance and Administrative Services of incidents involving potential financial irregularities, misappropriation of funds, or embezzlement within two business days of notification.

2. Notify Internal Audit of all applicable ARMS Incident Reports.

3. If warranted, prepare the State Property Incident Report, including information provided by Internal Audit where applicable, based on their preliminary investigation, for incidents involving potential financial irregularities.

4. If warranted, submit the State Property Incident Report, which has been reviewed by Internal Audit, to the State Bureau of Investigations within ten days of the initial receipt of the information or evidence.

E. Upon notification from Security, Internal Audit will:

1. Review ARMS Incident Reports and notify the Vice President for Finance and Administrative Services and Security if further investigation is necessary and if a State Property Incident Report is warranted.

2. Provide additional information, based on preliminary investigations, of the allegations of potential financial irregularities, misappropriation of funds, or embezzlement.

3. Review the State Property Incident Report before it is filed for incidents involving potential financial irregularities.

4. Conduct an investigation, review the results with the appropriate administrators, and make recommendations for improvements to the systems of internal controls.

F. In order to maintain confidentiality and prevent compromising any related investigations, employees should not attempt to conduct investigations or discuss the facts, suspicions, or allegations with anyone, unless specifically directed to do so.

G. Reports of known or potential fraud will be treated in the strictest confidence to the extent possible. Employees will not be subject to retaliation or retribution as a consequence of reporting known or suspected fraud.

H. Employees must direct all inquiries from the media or external parties to the Public Information Officer and Assistant to the President for Community Relations and Marketing Services.

I. Cases involving monetary losses to CPCC will be pursued for recovery of losses. The college reserves the right to seek redress via civil proceedings against individuals whose fraudulent acts have resulted in financial loss to the college, whether or not the individual concerned is criminally convicted of that fraudulent act.

Changes approved by Cabinet on April 4, 2005; May 14, 2007; May 5, 2014