Fraud Investigations

Background

As a faculty or staff member of Tufts University you have a responsibility to be cognizant of policies and procedures that encourage good ethical business behavior. The vast majority of our employees are ethical and conduct business with high standards that are part of our culture. However, the University, like all organizations, is not immune to fraudulent acts. Fraud undermines trust and depletes the University and the department involved of vital resources needed for operations. Every member of the Tufts community, regardless of his or her position, is expected to cooperate and assist in preventing or identifying fraud.

This policy is intended to cover three types of fraud against the University:

(1)   Theft of University assets (e.g., cash, checks, physical assets)

(2)   Self-enrichment at the Expense of the University (e.g., making personal purchases using the P-Card, inflating or falsifying travel and business expense reimbursement reports, kickbacks, bid rigging, using University resources for personal gain or for family members, friends and associates)

(3)   Recording False Entries to Official University Records, typically to hide poor operating performance or favorably inflate operating results (e.g., understating expenses, overstating revenue)

Note that fraud involving the intentional disregard of academic integrity, including the theft of intellectual property or falsification of research results, is addressed by the “Policy on Misconduct in Research and Scholarship”.

Theft of Tufts University Assets

A suspected theft of university assets (including cash, checks or property) by a Tufts faculty or staff member is criminal in nature and must be reported to the Tufts Office of Public Safety.

Self-Enrichment at the Expense of the University

Any suspected self-enrichment of an employee, or his or her family members, friends and associates at the expense of the University must be immediately reported. Reports can be made to the director of AMAS or through the Tufts anonymous reporting hot-line. If the incident is first reported to a supervisor, chairperson, director, dean, vice president, or other responsible person, that person must forward the information to the director of AMAS. Self-enrichment schemes detected through the Finance Division’s Disbursements Compliance Audit Program should also be reported to the director of AMAS.

Recording False Entries to Official University Records

Employees are required to report any suspected intentional falsification of an official University record to the director of AMAS or through the Tufts anonymous reporting hot-line. If the incident is first reported to a supervisor, chairperson, director, dean, vice president, or other responsible person, that person must forward the report to the director of AMAS.

Investigative Steps and Disciplinary Actions

Depending on the type of fraud that has been alleged, one or more representatives from the offices of Human Resources, University Counsel, AMAS and Public Safety will coordinate the investigation. The supervisor of the employee suspected of committing the fraud, and leadership within the affected school or division will also be alerted to the investigation.

It is the policy of Tufts University that any person is free to lawfully disclose whatever information supports a reasonable belief of suspected employee misconduct. The University is committed to protecting employees from interference when making such disclosures. An employee may not retaliate against an employee who has made a disclosure and is also prohibited from directly or indirectly using the official authority of his or her position or office for the purpose of interfering with the right of an employee to make a disclosure.

In general, any Tufts employee found to have intentionally perpetrated a fraud will face disciplinary action, up to and including termination of employment. After consulting with the senior academic or administrative leadership of the school or division where the individual accused of a fraud scheme is working, the decision whether or not to take disciplinary action, up to and including termination, will require the authorization of the executive vice president and the vice president of Human Resources. The accused employee’s immediate supervisor and senior staff within the affected school or division are prohibited from taking any disciplinary action without first obtaining this authorization.

Substantiated fraudulent acts exceeding $1,000 in value will be referred for criminal prosecution.  All material frauds (and immaterial frauds at the discretion of management) will be reported to the Tufts University Trustee Audit Committee.

Contact Information:

Vice President of Human Resources                                                  7-3283

Director of Human Resources-Medford                                              7-2446

Director of Human Resources-Boston/Grafton                                   6-6599

Director of Audit & Management Advisory Services (AMAS)               7-2068

University Counsel-Employment                                                        7-3336

Police Captain                                                                                   7-3978