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Business Procedures Manual

16.4 Reporting Wrongdoing

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Modified: November 14, 2014

The USG is committed to the highest ethical and professional standards of conduct in pursuit of its mission to create a more educated Georgia. This mission demands integrity, good judgment and dedication to public service from all members of the USG Community. USG employees have an affirmative duty to report wrongdoing in a timely manner and to refrain from retaliating against those who report violations or assist with authorized investigations. The USG also is committed to preventing and detecting fraud, waste, abuse, and other forms of wrongdoing and taking action when wrongdoing occurs. It is the policy of the USG to refer all criminal acts to law enforcement for investigation.

16.4.1 Conduct to Report

Modified: November 13, 2014

Wrongdoing is defined under this policy as violations of USG policies, state or federal law, violations of ethical and professional conduct and fraud, waste or abuse. Examples of wrongdoing include, but are not limited to: USG Code of Conduct violations, discrimination, harassment, research misconduct, academic misconduct and privacy violations. Fraud, waste and abuse are defined further as follows:

Fraud: A false representation of a matter of fact that is intended to deceive another. A fraudulent act may be illegal, unethical, improper, or dishonest and may include, but is not necessarily limited to:

  • Embezzlement
  • Misappropriation
  • Alteration or falsification of documents
  • False claims
  • Asset theft
  • Inappropriate use of computer systems, including hacking and software piracy
  • Bribery or kickbacks
  • Conflict of interest
  • Intentional misrepresentation of facts

Waste: The expenditure or allocation of resources in excess of need that is often extravagant or careless.

Abuse: The intentional, wrongful, or improper use of resources. Abuse may be a form of wastefulness, as it entails the exploitation of “loopholes” to the limits of the law, primarily for personal advantage.


16.4.2 Where to Report

Modified: November 13, 2014

Events presenting an immediate threat to life or property or that are obvious criminal acts should be reported to law enforcement. Employees should report other wrongdoing or concerns through the administrative processes and procedures established by their institutions and the USG. Unless otherwise indicated or circumstances make it inappropriate, employees should report wrongdoing through their supervisory chains. Other reporting avenues, however, are always available, including the institution’s internal audit department, the human resources department, the office of legal affairs and the corresponding departments at the University System Office, which include the internal audit department, the human resources department and the office of legal affairs. Wrongdoing and concerns also can be reported anonymously on the Ethics and Compliance Reporting Hotline, which is available 24 hours a day, 7 days a week at:

http://www.usg.edu/audit/compliance/reporting_contacts


16.4.3 Protection against Retaliation - Whistleblower Protection

Modified: November 13, 2014

Protections Afforded: USG employees may not interfere with the right of another employee to report concerns or wrongdoing, and may not retaliate against an employee who has reported concerns or wrongdoing, has cooperated with an authorized investigation, has participated in a grievance or appeal procedure, or otherwise objected to actions that are reasonably believed to be unlawful, unethical or a violation of USG policy. Violations of this policy may result in disciplinary action, which may include the termination of employment.

Conduct Prohibited: Retaliation is any action or behavior that is designed to punish an individual for reporting concerns or wrongdoing, cooperating with an investigation, participating in a grievance or appeal procedure or otherwise objecting to conduct that is unlawful, unethical or violates USG policy. Retaliation includes, but is not limited to, dismissal from employment, demotion, suspension, loss of salary or benefits, transfer or reassignment, denial of leave, loss of benefits, denial of promotion that otherwise would have been received, and non-renewal.

Written Procedures: Each institution shall maintain written procedures for receiving and investigating allegations of actions that violate the USG’s policy prohibiting retaliation. Violations of this policy should be reported through the administrative processes and procedures established by each institution. Alleged retaliation by an employee assigned to the University System Office should be reported to the Vice Chancellor for Human Resources.

False Reports / False Information: This policy does not protect an employee who files a false report or who provides information without a reasonable belief in the truth or accuracy of the information. Any employee who knowingly files a false report or intentionally provides false information during an investigation may be subject to disciplinary action, which may include the termination of employment.


16.4.4 Investigation of Malfeasance

Modified: November 13, 2014

Malfeasance is any conduct or act carried out by a public official that cannot be legally justified or conflicts with the law including, but not limited to, fraud, waste, and abuse. The USG Office of Internal Audit and Compliance has the primary obligation for investigating reported malfeasance involving the University System Office, institutional senior administrators, and institutions without an institutional internal auditor. Institutional internal audit departments have the primary obligation for malfeasance investigations at institutions.

The internal audit departments at both the institution and the University System Office may contact other departments, including the office of legal affairs and the department of public safety, to establish the necessary team to proceed with the review or investigation. The investigative team will attempt to keep source information as confidential as possible.


16.4.5 Malfeasance Reporting

Modified: November 13, 2014

Incidents involving suspected criminal malfeasance by an employee must be reported to the USG Chief Audit Officer once an initial determination has been made that employee malfeasance may have occurred. Malfeasance reports should be marked confidential and submitted in draft form. Malfeasance reports should include:

  • Institution’s name and point of contact , including the email address and phone number;
  • Description of the incident, including the incident time, date, location, improper activity, and estimated loss to the institution (if any);
  • Known suspect information, including the employee name, title, employment status (administrative leave, pending termination, etc.), and supervisor’s name; and,
  • Current case status, including law enforcement involvement and the results of any internal audit investigation.

The USG Chief Audit Officer, in consultation with the USG Office of Legal Affairs, shall transmit employee malfeasance reports to the Georgia Department of Law. The transmittal letter shall include an incident summary and may include a recommendation as to whether to pursue further investigation.


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