University Fraud, Waste & Abuse Reporting Policy

Purpose

This policy sets forth guidelines for reporting known or suspected fraud, waste and abuse within Willamette University (the University). The policy also provides for the protection of individuals who make good faith reports of suspected fraud, waste and abuse by confirming their protection from retaliation under the law and establishing a hotline provided by an independent third party, EthicsPoint.

Policy

The University has a stewardship responsibility over all resources entrusted to it. All employees of Willamette University shall report known or suspected instances of fraud, waste, and/or abuse. Matters can be reported to campus management, the University Controller, or through the reporting hotline that has been established with EthicsPoint. Campus managers who receive notice of suspected or known fraud, waste, and/or abuse are required by this policy to report such matters to the University Controller.

Employees who identify themselves and make a good faith report of suspected fraud, waste, or abuse are protected from retaliation, in accordance with ORS 659A. The University will maintain confidentiality for employees reporting suspected irregularities, misconduct, safety issues, or other concerns to the extent possible under the law.

Procedure:

1. The University contracts with EthicsPoint, an independent, third-party vendor, to provide this confidential and anonymous telephone and Internet system for reporting concerns.

2. Matters can be reported directly to campus management or the University Controller.

3. When employees do not feel comfortable discussing these matters directly with campus management or the University Controller, or they are implicated in the matter, reporting can be made through the EthicsPoint Hotline: 1.844.727.0818 or https://willamette.ethicspoint.com.

4. EthicsPoint reports concerns received on the hotline to the University Controller, who initiates investigation efforts of reported concerns in conjunction with necessary campus and external parties as deemed appropriate. If the University Controller is implicated, concerns are reported to the Senior Vice President for Finance and Administration. If both the University Controller and the Senior Vice President for Finance and Administration are implicated, concerns are reported to University Counsel.

Definitions

Suspected fraud, waste, or abuse is a reasonable belief or actual knowledge that fraud, waste, and/or abuse is occurring or has occurred. Concerns may include but are not limited to the following functional categories:

• Academic & Student Affairs
• Accounting & Financial
• Athletics
• Human Resources
• Information Technology
• Research
• Risk and Safety
• University Health Centers
• Other

Campus management and the President’s Office include the president, vice presidents, deans, directors, and division/department heads, as well as other managers authorized to determine and assign duties to university employees.