The Office of Audit & Compliance Review (OACR) is established to provide a central point for coordination of, and responsibility for, activities that promote accountability, integrity, and efficiency in the University. The OACR has the duty and responsibility to direct, supervise, and coordinate audits relating to the programs and operations of the University. To effectively fulfill this duty and responsibility, it is important that the OACR be aware of all audit and audit-related services to be received by the University and related entities, including direct support organizations.

Appropriate personnel shall work with the OACR and determine (1) what audit and audit-related services may best be provided by the OACR versus an outside source, and (2) the level of involvement by the OACR in procuring audit and audit-related services from outside the University. Whenever these services are provided by a source outside the University, a copy of the written results shall be provided to the OACR.

February 25, 2002

SUBJECT: Policy Against Fraudulent or Other Dishonest Acts

AUTHORITY: Sections §1001.74, §1001.75, and Part III of Chapter 12, Florida Statutes

Policy/Purpose: To guard against all fraudulent or other dishonest acts

Responsibility - All employees of the University of Florida are to observe the provisions of the Code of Ethics for Public Officers and Employees, Part III of Chapter 12, F. S., and the University's policy against fraudulent and other dishonest acts. Generally, employees abide by laws and regulation; however, incidents of fraudulent or other dishonest acts may occur. Administrators at all levels of management should set the appropriate tone by displaying the proper attitude toward complying with laws, rules, and regulations, and are responsible for establishing and maintaining proper internal controls which will provide for the security and accountability of the resources entrusted to them. In addition, administrators should be cognizant of the risks and exposures inherent in their area of responsibility, and be aware of the symptoms of fraudulent or other dishonest acts, should they occur. In those instances where internal controls need strengthening, the University's Office of Audit & Compliance Review may be consulted for assistance on how to enhance those controls.

Investigation - The University's Office of Audit & Compliance Review has been designated the official contact for reporting suspected fraudulent or other dishonest acts. Employees, with a reasonable basis for believing such acts have occurred, have a responsibility to report it to their supervisor, appropriate administrator, or the Office of Audit & Compliance Review . Supervisors and administrators at all levels of management who become aware of suspected fraudulent and dishonest activity, are to respond to the suspected activity in a consistent and appropriate manner and shall report the suspected activity to the Office of Audit & Compliance Review l. The University's Office of Audit & Compliance Review will then determine if an investigation is warranted. If it is determined that an investigation is warranted, the Office of Audit & Compliance Review shall be responsible for investigating the suspected fraudulent or dishonest act after consulting with the President, Office of the Vice President and General Counsel, applicable human resources/personnel offices, or other administrators as appropriate. Employees shall not confront the individual being investigated, or initiate investigations on their own, as such actions can compromise any ensuing investigation. In those instances where the Chief Audit Executive's investigation indicates criminal activity, the investigation shall be turned over to the university police or other appropriate law enforcement agency.

During all aspects of any investigation, the constitutional rights of all persons are to be observed. The investigation should be completed expeditiously and in accordance with established procedures. All employees are to cooperate fully with those performing an investigation pursuant to this policy.

Reporting - The results of investigations conducted by the Office of Audit & Compliance Review shall be communicated, either orally or in writing as determined by the Chief Audit Executive, to the University President and other appropriate persons.

Action - Employees found to have participated in fraudulent or dishonest acts will be subject to disciplinary action pursuant to collective bargaining agreements and university rules. Also, criminal or civil actions may be taken against employees who participate in unlawful acts. In those instances where disciplinary action is warranted, the University's Office of Human Resources or appropriate academic administrator(s) and the Office of the Vice President and General Counsel shall be consulted prior to taking such actions.

As provided for in Section §112.3187, F. S. (Whistle-blower's Act), individuals who report suspected fraudulent or other dishonest acts, and those cooperating with the ensuing investigation, will be protected from retaliatory action.