CUA

    The Catholic University Of America

    Financial Fraud Hotline and Reporting Procedures

Overview

The Catholic University of America has established the following procedures for:

    ? The receipt, retention, and treatment of allegations regarding suspected fraud of

    the University resources as well as any violations of University financial policies.

    ? The confidential, anonymous submission by University employees or other

    individuals of concerns regarding suspected financial fraud.

The University is committed to continual review and update of its policies and

    procedures. Therefore, these procedures are subject to modifications.

Scope

These procedures relate to allegations regarding wrongful financial acts, including,

    without limitation, the following:

    ? Fraud or deliberate errors in the preparation, evaluation, review or audit of any

    financial statement of the University;

    ? Theft or misappropriation of funds, supplies, property, or other resources;

    ? Forgery or alteration of University financial documents or computer files;

    ? Pursuit of a financial benefit or advantage in violation of the University’s conflict

    of interest policies;

    ? Deficiencies in or noncompliance with the University’s financial controls.

    Allegations outside this scope (for example, harassment, discrimination or unfavorable treatment) will be referred to the appropriate person or department.

Procedures

The University has adopted the following procedures:

Receipt of Allegations

    1. Employees or other individuals with concerns regarding financial fraud involving

    University resources may report their concerns to the University Internal Auditor

    through email, regular mail, telephone or the University’s hotline as follows:

    ? Office of Internal Audit:

    Cardinal Station, 297 Leahy Hall, Washington, DC. 20064

     Phone 202-319-6731, Email: internalaudit@cua.edu

    ? Anonymous Financial Fraud Hotline Phone Number:

    202-319-4500

    Treatment of Allegations Regarding Wrongful Financial Acts

1. Upon receipt of an allegation, the University Internal Auditor will (i) determine

    the type of allegation and (ii) when possible, acknowledge receipt of the

    allegation to the sender.

2. The Internal Auditor, working with General Counsel or such other persons or

    departments as necessary, will review allegations and as necessary investigate

    under the Board of Trustees’ Audit Committee’s general oversight.

3. Any allegation that the Internal Auditor has participated in, or is involved in, any

    wrongful financial acts shall be directed to the General Counsel.

4. Any final investigative report will be provided to the cognizant Vice President

    and the Treasurer and Vice President for Finance and Administration.

5. The University will take appropriate corrective action based upon the findings of

    the investigations.

6. The University will not discharge, demote, suspend, threaten, harass or retaliate in

    any manner against an employee or student in the terms and conditions of

    employment or educational opportunity based on the employee’s or student’s

    good faith allegations of wrongful financial acts.

7. Allegations will be handled in a confidential manner in order to protect the

    identity of person’s accused of financial wrongdoing before an investigation has

    been completed, or where an investigation has revealed no evidence that

    wrongdoing occurred.

8. In the event that the investigation into allegations of wrongful financial acts

    results in a finding that wrongful financial acts occurred, appropriate disciplinary

    action will be taken and will be in accordance with ?6.5.11 of the Staff Handbook

    (for staff employees) or the Faculty Handbook (for faculty members).

    Reporting and Retention of Allegations and Investigations

1. The Internal Auditor will maintain an appropriate record of calls received on the

    fraud hotline as well as email, Internal Audit office telephone or written

    allegations received under this policy.

    2. The Internal Auditor shall provide the Audit Committee of the Board of Trustees

    with a periodic report of allegations and investigations.

     Effective Date: _________

    Approved By: _____________

    6/27/05