Misuse of University Assets & Reporting Suspected Fraud
WPI places a high level of trust in you, its faculty and staff, and requires that university assets under your control be protected and properly safeguarded from loss and misuse. This responsibility rests with employees at all levels and throughout all departments. Employees cannot take or use for their personal benefit property belonging to the university. The university's property includes its confidential information. Employees may not, therefore, use for their own benefit or for the benefit of their family, or disclose to others, confidential university information except in the proper performance of their employment duties.
The overwhelming majority of university personnel are ethical and well intentioned and do their best to conduct business activities at the highest level of propriety. However, under certain circumstances, fraud may occur. 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 of fraud include untruthful fraudulent financial reporting to hide poor business results, expense report falsifications, dishonest or false worker compensation or insurance claims, kickbacks, bid rigging, misuse of university purchasing and travel credit cards, or theft of assets.
Fraud undermines trust and depletes the university and the department involved of vital resources needed for operations. Every member of the WPI community, regardless of his or her position, is expected to cooperate and assist in preventing or identifying fraud.
Policy on Reporting Fraud
Sound business conduct requires that each employee, as a basic condition of employment, assume responsibility for safeguarding and preserving the assets and resources of WPI, particularly those for which he or she is responsible. The following policy statements serve to remind us of that basic commitment and responsibility.
- All revenues generated by the university, and all expenditures for goods and services, must be recorded and accounted for within the financial accounting system of the institution.
- No false entries are to be made in the accounting records of the university for any reason. Moreover, no payment on behalf of the university is to be approved or made with the understanding that any part of such a payment is to be used for any purpose other than that described by the documents supporting the payment.
- The use of university fund or assets for any personal or unlawful purpose is prohibited.
- The use of any university equipment, supplies, or facilities for a revenue generating activity that benefits an individual employee is prohibited.
- No person in a supervisory or management position is to use the authority of that position to assign an employee to perform non-employment-related tasks.
- Managers have a responsibility to develop and implement controls to minimize opportunities for fraud to occur.
As a member of the WPI community, you are expected to report any instances of suspected fraud to the General Counsel. If an instance of suspected fraud is initially reported to a supervisor, department head, director, dean, vice president, or other responsible person, that person is to report the instance to the General Counsel. Suspected research misconduct should be reported to the Provost. Any theft of physical assets should be reported to the WPI Police at 508-831-5433.
It is the policy of WPI that any person is free to lawfully disclose whatever information supports a reasonable belief of suspected employee misconduct. The university will not tolerate retaliation toward or harassment of employees who report actual or possible misconduct. An employee may not retaliate against an employee who has made a disclosure and is also prohibited from directly or indirectly using the official authority of his or her position or office for the purpose of interfering with the right of an employee to make a disclosure. Such disclosures can be made to the General Counsel, the employee’s immediate supervisor, other appropriate administrator, or the anonymous third party reporting provider described below.
*Situations may exist where members of our community feel uncomfortable discussing these matters with their colleagues, supervisors, or the General Counsel. To assist with these particular situations, the University has an agreement with a third party anonymous reporting provider, EthicsPoint, Inc, to maintain a WPI internet application and call center for individuals to report any concerns related to financial, regulatory, compliance, environmental health and campus safety matters. The EthicsPoint’s application is designed to ensure that any communications will remain completely confidential in accordance with the wishes of individuals who make reports using this option. You may access this reporting option by going to the Accounting and Treasury webpage and clicking on “EthicsPoint Whisleblower”.
If presented with reasonable evidence of a suspected fraud, the General Counsel will conduct an investigation to determine if the reported suspicions of fraud are valid. The General Counsel will also inform the supervisor of any employee under investigation. If, based on the results of the investigation, the General Counsel believes that fraudulent activities have occurred, he or she will report the findings as appropriate, to the President, the Executive Vice President, the Provost, the Vice President for Human Resources, the Controller, and the Director of Public Safety/Chief of Police. All determinations of significant fraudulent activities will be reported in a timely manner to the Audit Committee of the Board of Trustees. The University will prosecute such activities to the fullest extent allowed by the law.
Questions & Answers
Q. What should I do if I notice that goods being ordered by a coworker for personal use are being charged to a department account?
A. The misuse of university assets for personal gain is improper and considered fraud. You should report your suspicions to your supervisor, department head, or the General Counsel as appropriate.
Q. I recently witnessed one of my fellow employees submitting false receipts for business travel. What can I do?
A. Report what you have seen to your supervisor, department head, or the General Counsel, as appropriate, for investigation and follow-up.
Q. I'm aware of fraudulent activity taking place at the university that I'd like to see stopped but don't want to get involved. Is there any way I can proceed?
A. The university encourages all faculty and staff members to come forward with any and all honest allegations of fraud or suspected fraud. However, employees may submit information anonymously to the Provost, the General Counsel, or through the above referenced anonymous third party reporting provider.