Fraud and Theft Prevention Policy

Scope of Policy

University of Kansas (KU) employees must comply with applicable state and federal law, Kansas Board of Regents policy, and University policy. Furthermore, a KU employee cannot be compelled by a supervisor or a University official to violate a law, Board of Regents policy, or University policy.

As a publicly supported institution, the University has a fiduciary responsibility to conserve, preserve, and efficiently use all University resources.

This policy applies to any known or suspected fraud or theft involving employees, customers, vendors, contractors, consultants, or other parties related to the University.

Prevention and Detection of Fraud and Theft

University employees shall not perpetrate, engage in, or otherwise facilitate the act of committing fraud and theft.

The Provost/Executive Vice Chancellor, Lawrence Campus, and Executive Vice Chancellor, Medical Center, are responsible for establishing the controls to prevent and detect fraud and theft. University managers are responsible for knowing the types of improprieties that might occur within their areas of responsibility and for identifying and assessing any irregularities. University employees are responsible for the prevention and detection of fraud and theft that might occur within the scope of their work assignments and for reporting any known or suspected fraud and theft.

Reporting Known or Suspected Fraud and Theft

Employees are responsible for immediately reporting known or suspected incidents of fraud, including theft and misappropriation of University assets, to either Internal Audit or the appropriate campus Public Safety office.

Any employee who has knowledge of fraud or theft of University assets by any person or organization, including another employee, and does not report it to University officials may be subject to disciplinary action, up to and including termination of employment.

If the initial notification is to Internal Audit , Internal Audit shall notify the appropriate campus Public Safety office and vice versa.

Investigation of Reports of Known or Suspected Fraud and Theft

The campus Public Safety office shall investigate allegations of fraud and theft in accordance with University established policies and procedures.

Internal Audit shall be responsible for ascertaining the extent of loss, and for reviewing and evaluating control and/or process failures related to the loss. Internal Audit will also notify the University Chief Financial Officer, Office of the General Counsel, the Provost/Executive Vice Chancellor, Lawrence Campus, and/or the Executive Vice Chancellor, Medical Center.

Any employee who suspects fraudulent activity should not attempt to personally conduct an investigation related to the activity. If the employee elects to notify department management first, then department management must immediately notify Internal Audit or the appropriate campus Public Safety office before taking any other action. Concerns about work performance and workplace behavior that are unrelated to fraudulent activity should be resolved by department management and Human Resources (Lawrence) or Human Resources (Medical Center): they should not be reported under the fraud and theft policy. If there are any questions about what constitutes fraud and theft, Internal Audit should be contacted.

Reports and investigations of allegations of fraud and theft ordinarily will be kept confidential to the reasonable extent possible under law and consistent with the need to conduct an adequate investigation and take corrective action.