91ÉçÇø

Premise
The 91ÉçÇø Foundation (91ÉçÇø Foundation or Foundation) is committed to the highest standards of moral, legal, and ethical behavior. These standards are outlined in the Code of Ethics. All members of the 91ÉçÇø Foundation, its staff, Board members, and volunteers have a responsibility for the stewardship of the 91ÉçÇø (University or 91ÉçÇø) and 91ÉçÇø Foundation resources. Internal controls and operating procedures are intended to protect assets and interests by detecting or preventing improper activities. However, there are no absolute safeguards against willful violations of laws, regulations, policies or procedures.

Policy Statement 
The 91ÉçÇø Foundation will investigate possible fraudulent or dishonest use or misuse of University or Foundation resources or property by the 91ÉçÇø Foundation staff, Board members, and volunteers. Anyone found to have committed fraud relevant to University or Foundation assets is subject to disciplinary action, up to and including termination or expulsion, and investigation by external criminal justice authorities when warranted.
The 91ÉçÇø Foundation Board of Directors is responsible for the administration, interpretation, and application of this policy.

Fraud, Fraudulent Act, or Misconduct: A deliberate act (or failure to act) with the intention of obtaining an unauthorized benefit, either for oneself or for the institution, by using deception or false suggestions or suppression of truth or other unethical means, which are believed and relied upon by others. Depriving another person or the institution of a benefit to which he or she is entitled by using any of the means described above also constitutes fraud. Examples of fraudulent acts include, but are not limited to, the following:

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• Forgery or alteration of documents
• Unauthorized alteration or manipulation of computer files
• Fraudulent financial reporting
• Misappropriation or misuse of University or Foundation resources (e.g., funds, supplies, equipment, facilities, services, inventory, or other assets)
• Authorization or receipt of payment for goods not received or services not performed
• Authorization or receipt of unearned wages or benefits
• Conflict of interest, ethics violations

NOTE: The 91ÉçÇø Foundation will not rely on a determination by a criminal justice authority to criminally prosecute as the basis for determining if an act is fraudulent. The presence of the elements named in the definition will determine if the act is fraudulent for internal disciplinary purposes.

Whistleblower: A person or entity making a protected disclosure is commonly referred to as a whistleblower. Whistleblowers may be staff, Board members, volunteers, students, vendors, contractors, or the general public. The whistleblower reports suspected fraudulent behavior. The whistleblower does not investigate the facts or determine the corrective or remedial action that may be warranted. The 91ÉçÇø Foundation is responsible for maintaining a system of internal controls which prevent, detect, or deter fraudulent or dishonest conduct. Each member of the 91ÉçÇø Foundation staff is expected to recognize risks and exposures inherent within his or her area of responsibility and to be alert for any indication of irregularity. 91ÉçÇø Foundation staff should contact the Audit Committee as soon as fraud is detected or suspected. Staff members who know or suspect that other staff members are engaged in a fraudulent act have a responsibility to report such activity to their supervisor or appropriate administrator. However, in the interest of confidentiality or if the staff member is uncomfortable reporting to his supervisor or administrator, the staff member may notify the Audit Committee directly by one of the methods described under Reporting a Fraud. Any staff member who is aware of a fraud and does not immediately report it will be subject to disciplinary actions. Staff members who report suspected fraudulent activity will be protected from reprisal or retaliatory action as stated in the Whistleblower Protection provisions. Whistleblowers should not confront the individual under suspicion or initiate investigations on their own. Such action may compromise any ensuing investigation and violate the individual’s constitutional rights.

IMPORTANT: All claims of fraudulent activities must be made in good faith. Baseless allegations, made with disregard for truth or accuracy, or frivolous complaints will not be tolerated. People making such allegations may be subject to institutional disciplinary action and/or legal actions by the individuals accused of fraudulent conduct. The Audit Committee will coordinate the investigation and resolution of reported fraudulent activities with appropriate 91ÉçÇø departments (e.g., Security, Human Resources, Risk Management and Safety) and external law enforcement officials/agencies as appropriate and in accordance with the following guidelines:

• All investigations will be conducted in the strictest confidence.
• If an investigation reveals theft/fraud, charges will be filed with the appropriate criminal justice authority.
• Restitution, including costs associated with the investigation, may be required from the accused.
• Human Resources will determine the extent to which disciplinary action, in accordance with personnel policies and procedures, will be imposed.

Reporting a Fraud
Any person may report allegations of suspected improper activities by one of the following methods:

1. Report directly to one’s supervisor or appropriate administrator, either orally or in writing. The supervisor or administrator must contact the Audit Committee as soon as a suspected fraud is reported.
2. File a written report addressed to Chair of Audit Committee, Attn: Jeffrey L. Wilmes, 4115 Wyndclyff Court, Evansville, IN 47711-6901.
3. File a written report via e-mail to jeffwilmes@outlook.com.

The identity of the individual conveying information will remain confidential to the extent possible within the legitimate needs of the law and the investigation. A whistleblower may remain anonymous. Because investigators are unable to interview anonymous whistleblowers, it may be difficult to evaluate the credibility of the allegations. Therefore, it is critical that anonymous whistleblowers provide detailed information and sufficient corroborating evidence to justify their claims that a fraudulent act has occurred. Unspecified or broad allegations of wrongdoing cannot be investigated.

Whistleblower Protection
The 91ÉçÇø Foundation cannot guarantee confidentiality, but generally, the whistleblower’s identity will not be disclosed unless (1) the person agrees to be identified; or (2) identification is required by legal proceedings. For having made a report of fraud or misconduct, the whistleblower may not be dismissed from employment or expelled from school; have salary increases or employment related benefits withheld; be transferred or reassigned; be denied a promotion or grade the employee or student otherwise would have received; or be demoted, penalized, or threatened in any way. Whistleblowers who believe they have been retaliated against may file a written complaint with the Chair of the Audit Committee. A proven complaint of retaliation shall result in disciplinary action, up to and including dismissal, against the retaliating person. 91ÉçÇø Foundation staff members have whistleblower protection under Indiana Code 5-11-5.5. Nothing in this policy shall be construed in such a way as to conflict with the .