Like all organizations, Calvin College is faced with risks from wrongdoing, misconduct, dishonesty, and fraud in its financial operations. As with all business exposures, we must be prepared to manage these risks and their potential impact in a professional manner.
The impact of financial misconduct and mishonest may include:
- the actual financial loss incurred.
- damage to the reputation of our organization and our employees.
- negative publicity.
- the cost of investigation.
- loss of employees.
- loss of students.
- damaged relationships with our contractors and suppliers.
- damaged employee morale.
Our goal is to establish and maintain a business environment of fairness, ethics, and honesty for our faculty, our staff, our students, our alumni and donors, and anyone else with whom we have a relationship. To maintain such an environment requires the active involvement of every employee every day.
Calvin College is committed to the deterrence, detection, and correction of any misconduct and dishonesty in all of its financial operations. The discovery, reporting, and documentation of such acts provides a sound foundation for the protection of innocent parties, the taking of disciplinary action against offenders up to and including dismissal where appropriate, the referral to law enforcement agencies when warranted by the facts, and the recovery of assets.
The purpose of this document is to communicate policy regarding the deterrence and investigation of suspected financial misconduct and dishonesty by faculty, staff, and students, and to provide specific instructions regarding appropriate action in case of suspected violations.
Definition of Financial Misconduct and Dishonesty
For purposes of this policy, “financial misconduct and dishonesty” includes but is not limited to:
- theft or other misappropriation of assets, including assets of the college, our suppliers, or others with whom we have a business relationship.
- misstatements and other irregularities in company records, including the intentional misstatement of the results of operations.
- financial wrongdoing.
- forgery or other alteration of documents.
- fraud and other unlawful acts.
- any similar acts.
Calvin College specifically prohibits these and any other illegal activities in the actions of its faculty, staff, administrators, students, and others responsible for carrying out the college’s financial operations.
It is the responsibility of every student employee, employee, supervisor, manager, and executive to immediately report suspected financial misconduct or dishonesty to either their supervisor or divisional vice president. Supervisors, when made aware of such potential acts by subordinates, must immediately report such acts to the Director of Human Resources, the Director of Financial Services, their divisional vice president, or the President’s Office. Any reprisal against any employee or other reporting individual because that individual, in good faith, reported a violation is strictly forbidden.
Due to the important yet sensitive nature of the suspected violations, effective professional follow up is critical. Managers, while appropriately concerned about “getting to the bottom” of such issues, should not in any circumstances perform any investigative or other follow up steps on their own. Concerned but uninformed managers represent one of the greatest threats to proper incident handling. All relevant matters, including suspected but unproved matters, should be referred immediately to those with follow up responsibility as described in the Faculty Handbook Chapter 6, Staff Handbook Appendix B, or the Student Conduct Code Article V and Appendix G.
To facilitate reporting of suspected violations, especially in those situations where the reporting individual wishes to remain anonymous or has not received a satisfactory response, the college has established a third-party telephone hotline. The details of this hotline are found in the attached Appendix A. Campus Conduct Hotline.
Additional Responsibilites of Supervisors
All employees have a responsibility to report suspected violations. However, employees with supervisory and review responsibilities at any level have additional deterrence and detection duties. Specifically, personnel with supervisory or review authority have three additional responsibilities.
- First, become aware of what can go wrong in your area of authority.
- Second, put into place and maintain effective monitoring, review, and control procedures which will prevent acts of wrongdoing.
- Third, put into place and maintain effective monitoring, review, and control procedures which will detect acts of wrongdoing promptly should prevention efforts fail.
Authority to carry out these three additional responsibilities is often delegated to subordinates. However, accountability for their effectiveness cannot be delegated and will remain with supervisors and managers.
Assistance in effectively carrying out these responsibilities is available upon request through the Academic Deans, the Director of Human Resources, the Director of Financial Services, and the divisional vice presidents.
Board of Trustees AF/IS Committee – reviewed with consent and referred to college governance for approval, May 18, 2006
Cabinet – Approved, July 19, 2006
Planning and Priorities Committee – Approved (w/ revisions), December 14, 2006
Faculty Senate – Approved, March 5, 2007
Board of Trustees – Approved, May 18, 2007