Business Office “Count on Satisfaction” Cynthia Villarreal Accounting Group Supervisor 872-4610 cvillar@southtexascollege.edu S T C G u i d l i n e s What would you do? It’s 8 am Monday morning and you are waiting to clock in at your building. You notice the employee in front of you clocks in, exits the building and drives off in their car. a) b) c) d) e) You clock in and go on with your day You inform your supervisor You inform the Director of Human Resources You contact TimeForce (Annie Ochoa) b&c What would you do? You become aware that a co-worker has been running personal errands when they should only be commuting for work related activities. a) You inform the employee that it’s not acceptable b) You inform their supervisor c) You inform your supervisor d) You don’t say anything Purpose Fraud-intentional deception to unlawfully deprive the College of something of value Waste-extravagant, careless or needless expenditure of College funds, incurring of unnecessary expenses, mismanagement of college resources or property or the consumption of College property that results from deficient practices, systems, controls or decisions Abuse-intentional, wrongful, or improper use or destruction of College resources; excessive or improper use of an employee or official’s position in a manner other than its rightful or legal use 2014 Global Fraud Survey Occupational Fraud-the use of one’s occupation for personal enrichment through the deliberate misuse or misapplication of the employing organization’s resources or assets. Asset Misappropriation – 85% Corruption – 37% Financial Statement Fraud – 9% 2014 Global Fraud Survey Fraud Triangle When these three sides of the triangle are present, there is a much higher than normal chance of an individual committing a fraud. Pressure-motivates the crime Opportunity-the method by which the crime can be committed Rationalization-justify the crime to make it acceptable 2014 Global Fraud Survey Behavioral Red Flags 2014 Global Fraud Survey Detection Methods Proactive Tip – 42% Management Review – 16% Internal Audit – 14% Passive Accident – 7% Account Reconciliation – 7% Document Examination – 4% External Audit – 3% Surveillance/Monitoring – 3% Notified by Law Enforcement – 2% IT Controls – 1% Confession – 1% Doing What’s Right Anonymous Fraud & Ethics Hotline 1-800-482-5158 This toll-free number is staffed by The Network, an independent organization operating 24 hours a day, 7 days a week. You do not have to give your name. An Interview Specialist documents your concern, assigns you a personal reference number, and relays your concerns to the company. Examples of Acts of Fraud, Abuse and Other Improprieties Theft or misappropriation of funds False overtime Sick abuse Use of College property for personal benefits Waste of supplies Fictitious vendor, employee or student payments False reimbursements Forgery of altercation of documents Unauthorized use of records or access to information systems Falsification of reports to management or external agencies Authorizing or receiving compensation for goods not received or services not performed Improper handling or reporting of financial transactions South Texas College Guidelines for Reporting and Investigating Suspected or Known Fraud, Abuse and Other Improprieties S T C G u i d l i n e s http://hr.southtexascollege.edu/forms/policies/policies_reporting_fraud_procedures.pdf 1. Introduction STC is committed to creating an environment where fraud, waste, abuse and other improprieties are not tolerated Responsibilities for educating employees Responsibilities for internal controls Responsibilities for identifying and evaluating risks 2. Purpose Procedures and responsibilities or reporting and investigating incidents Taking remedial actions Reporting evidence 3. General Applies to all employees Requires employees to detect and report College will pursue legal remedies Texas Whistleblower Act Requires employees to cooperate Immediately contact appropriate personnel 4. Examples of Acts of Fraud, Abuse and Other Improprieties Activity: Is done with the intent to conceal Violates the employee’s fiduciary duties to the College Is committed for the purpose of direct or indirect financial benefit to the employee Costs the College assets, revenues, or reserves 5. Employee Responsibilities Report the act to your immediate supervisor If the supervisor has participated in or condoned the act, report the matter to the next highest level of supervisor or management Director of Human Resources Anonymous Fraud and Ethics Hotline State Auditor’s Office Fraud, Waste and/or Abuse Hotline 5. Employee Responsibilities Employee should prepare written report Department where the act is occurring What is occurring When it occurred Who is involved How is it occurring Employee will refrain from further examination of incident with anyone other than proper personnel 6. Restitution Appropriate action will be taken to recover assets lost Will include cost of investigation, recovery or other associated costs 7. Internal Control Deficiencies Identify areas or practices in College that require modification Internal Auditors will recommend corrective actions and shall follow-up on their recommendations 8. Employee Disciplinary Actions An employee found to have participated who hinders a fraud inquiry or investigation by making a false or misleading statement who has knowledge of fraud of a dishonest act, but fails to report it according to these guidelines Shall be subjected to disciplinary action 9. Acting on Evidence of Fraud College is responsible to investigate acts and to act on evidence Appropriate personnel will gather facts and evidence Appropriate experts, consultants and law enforcement will be engaged as required 9. Acting on Evidence of Fraud Employee may be reassigned, relieved of duties, etc, pending the outcome of the investigation A report will be prepared Take appropriate action against the employee found to have committed the act 10. Employee Training and Acknowledgement Training related to reporting is provided to all employees 11. Acting in Good Faith Anyone reporting acts, must act in good faith and have reasonable grounds for believing the information disclosed is valid. Reports proven to be unsubstantiated and proven to be done maliciously, recklessly, or falsely will be viewed as a serious disciplinary offense and may result in discipline, up to and including termination of employment. 12. Confidentiality Reports and investigations of incidents of fraud, waste, and/or abuse shall be kept confidential. Disclosure of reports to individuals not involved in the investigation will be viewed as a serious disciplinary offense and may result in discipline, up to, and including termination of employment. Doing What’s Right If you ever have a concern regarding • • • violation of policies illegal activities unsafe activities Doing What’s Right Such as the following: • • • • • Theft, misappropriation of funds, false request for reimbursement, unauthorized use of records or access to information systems or fictitious vendor, employee, or student payments Doing What’s Right Don’t keep it to yourself. • You have the responsibility to report it to the appropriate personnel. Report the act per normal channels: • your immediate supervisor or • if your immediate supervisor has participated in or condoned the act, report the matter to the next highest level of supervision or management or to • the Director of Human Resources Doing What’s Right If you don’t feel comfortable discussing the issue within normal channels, you may call The Network, an independent company which provides an anonymous reporting service for hundreds of companies worldwide. http://finance.southtexascollege.edu/businessoffice/forms/alerts/ Alert_2006_08.pdf Doing What’s Right This service is not intended as a substitute for speaking directly with management. It is an option that is always available if you want to help, but prefer not to give your name. Fraud Hotline Flyer http://finance.southtexascollege.edu/businessoffice/forms/Fraud_Hotline_Flyer.pdf Fraud Survey F r a u d s u r v e y http://finance.southtexascollege.edu/businessoffice/survey.html Questions