The Catholic University Of America
Financial Fraud Hotline and Reporting Procedures
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.
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.
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: firstname.lastname@example.org
? Anonymous Financial Fraud Hotline Phone Number:
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
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
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: _____________