Statement of Ethical Conduct Our Commitment To Integrity And Ethical Conduct 1 Statement of Ethical Conduct • Driven by the University’s mission of teaching, research, and patient care – Sets expectation of highest standards of ethical conduct – Commits to upholding the reputation of the University – Encourages compliance with applicable laws, regulations, and University policies – Does not condone retaliation for any good faith report of improper activity 2 Statement of Ethical Conduct • Be honest, ethical, truthful • Obey the law • Follow University policies and procedures 3 What Is Honesty? • Honesty is – Fairness – Forthrightness – Straightforward conduct – A refusal to lie, steal or deceive • Honesty is taking responsibility for one’s own actions 4 What Is Fraud? • Fraud is an intentional act calculated to deceive by – Affirmative act – Concealment – Omission • …that results in damage to an individual or organization and violates a legal or equitable duty owed 5 Impact Of Dishonesty And Fraud • Fraud and dishonesty cause – The destruction of institutional and personal reputation, loss of respect, and loss of public esteem – Criminal and civil penalties, fines, suspension, terminations and the destruction of careers – U.S. organizations to lose an estimated five (5%) percent of their annual revenues 6 Identifying And Reporting Fraud • The five most reported schemes of fraud are: – BILLING SCHEMES – employee causes the business to issue payment for fictitious goods or services or payment for services that were personal to the employee – PAYROLL SCHEMES – employee caused the business to issue payment for compensation for false claims of work – EXPENSE REIMUBURSEMENT SCHEMES – employee makes a claim for reimbursement for a fictitious, or inflated, or personal expense – CHECK TAMPERING – employee steals funds by forging or altering a business check – CASH REGISTER DISBURSEMENT SCHEMES – employee makes false entries on a cash register to conceal removal of currency 7 Who Reports Fraud, And How? • Fraud is discovered 46% of the time due to a tip provided by an individual – Of the fraud tips provided, 59.6% come from company employees – 35% from customers or vendors – 5% by internal or external audit and by chance • Organizations with anonymous reporting systems cut their fraud losses by 50% 8 What Is Ethical Conduct? • Conduct conforming to the law and regulations, professional standards, and the policies of the University – A Statement of Ethical Conduct expresses a set of values and defines the purpose of an individual or organization – A Statement of Ethical Conduct says: “This is who we are and this is what we stand for” 9 What Is Compliance? • A willingness to follow a prescribed course of action – Acting according to certain accepted standards – Observance of official requirements 10 Columbia’s Compliance Hotline 11 Compliance Hotline • A 24/7 confidential channel for employees to report or seek guidance on incidents of financial impropriety • Enhances the set of existing services and channels that support integrity and compliance – – – – – EVP for Research Billing Compliance Human Resources Internal Audit Ombuds Office 12 Why Is This Important? • We want to give employees every possible means to report fraud, abuse, and conflicts of interest -- and the understanding of why it is important to do so – Less than one-half of all organizations encourage discussion of moral dilemmas and criticism of unethical conduct 13 Columbia’s Compliance Hotline • Provided and administered by a third party -Global Compliance • 24-hour telephone and web-based channels – (866) 627-3768 – https://www.submitreport.com/columbiauniversity.jsp • Confidential intake and report handling – Option to report anonymously 14 Focus Of The Compliance Hotline • University-wide scope – Fraud and financial improprieties – Research misconduct – Conflicts of interest – Breaches of confidentiality or destruction of information – Discrimination or harassment 15 Options -- How, Where to Report • If possible, reach out to your supervisor first – As an alternative, identify the proper channel for seeking guidance, reporting, or resolution – Compliance Hotline 16