Fraud & Whistleblower Policy

Fraud & Whistleblower Policy

The SUNY Board of Trustees adopted a SUNY System Fraud Policy at its March 2013 Board Meeting.  The Fraud Policy helps to set the tone of the organization and communicate to all employees the requirement for honest behavior, ethical conduct, and fiduciary oversight with SUNY funds, resources, and property. At this meeting, the Board of Trustees also amended the existing Fraud Procedures. SUNY Delhi, in accordance with the SUNY Board of Trustees, has developed a Campus Fraud Policy and reporting mechanism.

SUNY Delhi Fraud Policy

SUNY Delhi is committed to upholding the highest standard of honest behavior, ethical conduct, and fiduciary responsibility with respect to campus funds, resources, and property. As such, SUNY Delhi seeks to prevent and detect any fraud or irregularities and will diligently pursue any instance that involves SUNY Delhi related activities or business.

Fraud and irregularities include activities that are: (1) a misappropriation of assets; (2) in violation of or non-compliant with any campus, SUNY, New York State, or federal law, regulation, policy or procedure; (3) economically wasteful; (4) an indication of gross misconduct or incompetency; or (5) an unethical, improper, or dishonest act.

It is the policy of SUNY Delhi that all members of the campus community:

  • comply with all campus and SUNY policies and procedures; and New York State and federal laws, and regulations;
  • practice honesty and integrity in fulfilling their responsibilities;
  • observe high standards of business and personal ethics in the conduct of their duties and responsibilities;
  • help ensure the prevention and detection of fraud and irregularities;
  • be familiar with the types of fraud and irregularities that might occur in their area;
  • be alert for any indication that fraud or irregularities might exist in their area; and
  • promptly report any known or suspected fraud or irregularities involving SUNY or affiliated entity funds, resources, property, or employees.

All members of the SUNY Delhi community are expected to report any known or suspected fraud or irregularities. Generally, an individual may discuss the concern directly with a supervisor; however, if the individual is not comfortable speaking with the supervisor, the individual is not satisfied with the supervisor's response, or the individual does not have a supervisor (such as a student), the individual may report the concern to the campus' designated officer, any campus fraud hotline, or SUNY's System Administration Fraud Hotline.

To report suspected fraud or irregularities to the campuses designated officer, Amy Brown:

Individuals have the option of either providing contact information or reporting the information anonymously. While not required, providing contact information will enable the reviewer to contact the individual to clarify the information being provided. At a minimum, individuals should provide key information such as a description of the incident; individual(s) involved; and financial loss, if any. When requested, SUNY Delhi will make every effort to handle all information received confidentially, to the extent permitted by law. Consistent with New York State laws, employees or other persons who lawfully report suspected improprieties shall not suffer discharge, demotion, suspension, threats, harassment, discrimination, or other retaliation as a result of making such a good faith report.

All complaints will be reviewed objectively and without regard to the suspected individual's length of service, position, title, or relationship with SUNY Delhi.

Whistleblower Policy

It is the policy of SUNY that employees and individuals who lawfully report suspected fraud, waste, or abuse shall not suffer discharge, demotion, suspension, threats, harassment, discrimination, or other forms of retaliation for making such reports in good faith.

Retaliation

Consistent with New York State laws, employees or other persons who lawfully report suspected improprieties shall not suffer discharge, demotion, suspension, threats, harassment, discrimination, or other retaliation as a result of making such a good faith report. Retaliation against anyone who has made a report in good faith under this process is strictly prohibited.

Please also note, intentional use of this process to make false allegations may subject the reporter to disciplinary action.

Through the revised procedure, campuses will be required to report all frauds to the Office of University Audit so they may be tracked and monitored by the Fraud Committee using a standard form, and report to the Office of the University Auditor any contact from the New York State Attorney General, the Inspector General, or any other outside agency regarding any investigation.