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Reporting and Investigating Fraudulent or Other Wrongful Acts

Policy Title: Reporting and Investigating Fraudulent or Other Wrongful Acts
Type of Policy: UFHR – ER
Effective Date: July 1, 2015
Last Revised: September 25, 2018

  1. Purpose
  2. The purpose of this policy is to provide guidance for faculty and staff to understand reporting expectations for known or suspected fraudulent or wrongful acts and outline the basic investigative responsibilities of the Office of Internal Audit (OIA).

  3. Scope
  4. This policy applies to all UF faculty, staff, volunteers, and students who may have access to university resources and funds.

  5. Policy Statement
  6. The University of Florida is committed to adhering to the highest ethical and business practices, including responsible use and management of university resources and funds.

  7. Procedures
    • 4.1 – Reporting Obligations
      Staff and academic personnel with a reasonable basis for believing fraudulent or wrongful acts have occurred have a responsibility to report such incidents to OIA and should not directly confront the individuals who may be investigated. Employees also should not initiate investigations on their own because such actions can compromise any ensuing investigations.

      The OIA works in consultation with UF Human Resource, university administrators, law enforcement personnel, when appropriate, and other levels of management in instances where fraud, including workers’ compensation fraud, research misconduct, p-card abuse, inappropriate use of funds, or other wrongful acts are suspected.

      Employees reporting instances of inappropriate acts by others, as well as anyone participating in investigations involving wrong-doing of this type may be protected by Section 112.3187, Florida Statutes (Whistle Blower’s Law), and the University’s protection from retaliation in the workplace as stated in UF Regulation 1.0101.

      OIA is also available to assist managers with ensuring proper internal controls are in place to assure best business practices are being observed and assist in preventing and deterring fraudulent and other wrongful acts.

    • 4.2 – Internal Audit Investigations
      In those instances where the OIA’s investigation indicates the probability of criminal activity, the investigation will be turned over to the UF Police Department (UFPD), or other appropriate law enforcement agency.

      An investigation will be completed expeditiously but always in a thorough manner and in accordance with established procedures. It is the duty of all employees to cooperate fully with those performing an investigation pursuant to this policy.

      The constitutional rights of those involved always will be observed. When appropriate, the results of an investigation conducted by the OIA will be communicated in a written report to the appropriate university administrators and to the president of the university.

    • 4.3 – Policy Inquiries
      The following is the department, office, or individual responsible for overseeing implementation of, and assuring compliance with, this policy. Any individual with questions about the policy should contact:

      Office of Internal Audit

      903 W. University Avenue
      P.O. Box 113025
      Gainesville, FL 32611-3025
      Phone: (352) 392-1391
      Email: auditor@ufl.edu (to expedite a response, please include the phrase “Fraudulent and Wrongful Acts” in the subject line of any email inquiries or reports)

  8. Enforcement
    Employees found to have participated in fraudulent or other wrongful acts will be subject to disciplinary action, up to and including termination of employment and prosecution if appropriate.

    Individuals who report suspected fraudulent or other wrongful acts under Section 112.3187, Florida Statutes (Whistle Blower’s Law), and those cooperating with the ensuing investigation will be protected from retaliatory actions.

Resources

UF Reg. 1.008 Disruptive Behavior
UF Reg. 1.0104 University of Florida Ethics Policy
Office of Internal Audit
Confidential/Anonymous Hotline
Employee Relations – Complaint Filing Options
UF Reg. 1.0101 Policy for Dealing with Conduct in Research
Section 112.3187, Florida Statutes (Whistle Blower’s Law)

Policy History

Revision Date Author Description
07/01/15 Office, Department/Unit Policy Adopted
09/25/2018 OIA & UFHR – Employee Relations General policy update and adoption of UF HR policy template