University of Vermont



INVESTIGATION PROTOCOL

Purpose
The University is committed to conducting its affairs in accordance with its principles of behavior outlined in its Code of Business Conduct and University policies. This protocol establishes an administrative process for dealing with allegations of misconduct reported under the Code of Business Conduct so that the integrity of business conducted at the University of Vermont may be preserved.

Reporting Concerns
As outlined in Code of Business Conduct reports of suspected misconduct are to be made to a responsible official or Office of Audit Services. Suspected fraudulent activity should be reported to the Office of Audit Services. Reporting channels outlined in specific University policy should be followed.

The Chief Internal Auditor shall keep the President, General Counsel and the Chair of the Audit Committee informed of any potentially serious or widespread compliance issues or defalcations.

Expectations of Employees
All employees are expected to cooperate and be truthful in the University's investigation of allegations.

When fraudulent activity is suspected, administrators:
  • should not contact the person suspected to further investigate the matter or demand restitution,
  • should not discuss the case with anyone other than the Audit Services Office, the Office of General Counsel, or a duly authorized law enforcement officer,
  • should direct all inquiries from any attorney retained by the suspected individual to the Office of General Counsel, and
  • should direct all inquiries from the media to the University Communications Office, or in the event that the Communications Office cannot be contacted, to the Office of General Counsel.
Fair Treatment
Persons assisting in the investigation shall be reminded of the University's whistleblower protections against retaliation in cases where the identity of the whistleblower may be compromised in furtherance of the investigation.

Individuals that are the subject of an allegation shall be notified as long as the investigative officer concludes it will not risk the integrity of the investigation and evidence of wrongdoing is found and reported on.

Investigation Steps:
  1. The investigative auditor shall evaluate the issues raised and refer the matter to the appropriate University offices as may be required during the investigation and in accordance with University policy.
  2. Investigation Outcomes.
    1. When the fact finding produces no evidence of misconduct or defalcation, the Office of Audit Services shall report the outcome to the cognizant University administrator.
    2. Incidents of minor misconduct or noncompliance may be referred to departmental management or other appropriate University offices for resolution. In these instances the investigation shall be a fact finding function in order to determine whether internal control deficiencies exist.
    3. If the investigation determines that substantial misconduct or defalcation occurred or likely occurred, the Office of Audit Services shall report on the findings to the President, Cognizant Vice President or Provost, appropriate responsible official, and General Counsel. Potential criminal activity will also be reported to Police Services. Risk Management will be notified of any defalcation that may be covered under University insurance. In addition, the Audit Committee of the Board of Trustees shall be notified of any allegation involving senior management (Vice President or above) and any fraud with an aggregate value of $10,000 or greater.
    Note: The Chief Internal Auditor retains the authority to report any matter to University administration or the Board of Trustees as he/she deems appropriate.
  3. If wrongful conduct is determined to have occurred the appropriate University official will initiate disciplinary action in a manner consistent with applicable University policy and procedure.
  4. Police Services is responsible for referrals made to the Vermont State Attorney's Office for potential criminal prosecution.
  5. The Office of Audit Services shall maintain the records and supporting documents related to all investigations.
  6. All reasonable efforts shall be made to complete the investigative review within 90 days. Any inquiries anticipated to extend beyond 90 days will be reviewed and approved by the Chief Internal Auditor.
Effective Date: 7/17/09

Last modified August 13 2012 02:17 PM

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