FRAUD AND IRREGULARITIES /
The Fraud and Irregularities / Compliance Hotline is a support process within our organizational compliance program.
It is SUNY policy that members of the SUNY community:
- comply with SUNY policies and procedures, 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.
It is SUNY policy 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.
What to report here
For the purpose of the hotline and other reporting methods covered here, fraud and irregularities include activities that are:
- misappropriation of assets;
- in violation of or non-compliant with any SUNY, New York State, or Federal law, regulation, policy or procedure;
- economically wasteful;
- an indication of gross misconduct or incompetency; or
- an unethical, improper, or dishonest act. Examples of improprieties include, but are not limited to, the following:
- Theft of any State or SUNY asset including, but not limited to money, tangible property, trade secrets or intellectual property;
- Misappropriation, misapplication, destruction, removal, or concealment of State or SUNY property;
- Inappropriate use of computer systems, including hacking and software piracy;
- Unauthorized disclosure of confidential or proprietary information;
- Unauthorized disclosure of student educational records, personal information, or medical information;
- Authorizing or receiving compensation for hours not worked or covered by appropriate and available leave;
- Fraudulent or otherwise deceptive financial reporting;
- Credit card and travel expense fraud;
- Use of staff to perform personal errands, services or tasks;
- Alteration or falsification of documents;
- False claims by students, employees, vendors or others associated with SUNY; and
- Bribery, kickbacks, bid rigging and conflicts of interest.
What not to report here
Activities described above that may constitute fraud or irregularities may also be covered by existing policies and procedures on specialized topics. Such activities may still be reported under this policy, but will be referred for handling to the extent such other procedures exist. Examples include:
- Employment grievances or complaints
- Discrimination or sexual harassment complaints
- Student academic grievances or academic dishonesty
- Allegations of Research Misconduct can be directed to the Research Integrity Officer (RIO). Research Misconduct is defined as fabrication, falsification, or plagiarism or other practices in the conduct of research, scholarly, or creative activity that seriously deviate from those that are commonly accepted within the academic community for proposing, performing, or reviewing research, or in reporting research results. Misconduct in research does not include honest error or differences of opinion. The RIO at Binghamton University is the Assistant Vice President for Research Compliance and can be reached at (607) 777-3532 or at email@example.com. For more information, please visit https://www.binghamton.edu/research/compliance/responsibleconductofresearch.html
- Complaints related to construction administered by the State University Construction Fund (SUCF) or the Dormitory Authority of the State of New York (DASNY) are generally the responsibilities of those entities.
If you need help finding a University Policy, you should contact the University Ombudsman.
If you suspect a fraud or dishonest or questionable act...
do not try to question anyone or otherwise investigate the matter yourself. Employees with reason to believe fraud or irregularity has occurred are responsible to report incidents. Students and other interested individuals are strongly encouraged to report known or suspected acts of fraud, waste or abuse as well. Please familiarize yourself with the activity definitions above before filing a report.
What we need to know
To best investigate reports, we need to know the following:
- Your name and contact information, unless you opt to remain anonymous
- A description of the suspected wrongdoing (what, where, when and how) including dates/times and if the acts are continuing
- The individuals involved in the alleged wrongdoing and a description of their involvement (who)
- Names of any witnesses
- The potential financial loss
Include as much detail as possible - all information helps.
Reports will be treated with discretion and confidentiality to the extent permitted by law. However, this confidentiality is not absolute because of legal or other requirements (e.g., discovery in litigation, government investigations, etc.) and situations where the University would need to use the information to protect the University's interests. The University will do everything it can to protect a reporter's identity during the investigation and handling of a matter, but in some limited situations the person(s) being investigated may be able to ascertain who the reporter is just by the nature of the facts or the contextual situation that gave rise to the report. Retaliation against anyone who has made a report in good faith under this process is strictly prohibited. Intentional use of this process to make false allegations may subject the maker to disciplinary action.
If you are a supervisor, department head or university official and you receive a report of known or suspected fraud or irregularity from any party, you should contact one of the offices below immediately. Do not confront, question, notify or terminate the suspected employee or accept the resignation of an employee who is suspected of, or admits to, fraudulent conduct.
How to report
In addition to reporting via the Binghamton University Compliance Hotline 607-777-5049, you may report your concerns of known or suspected acts of wrongdoing to one or more of the following:
- Your Supervisor or Head of Department
- Internal Audit:
- James Huth, Auditor (607)777-2128
- James Huth, Auditor (607)777-2128
- University Police:
- Risk Management and Administrative Compliance:
- Eric Backlund, Director (607)777-7475
- Eric Backlund, Director (607)777-7475
All reports are treated seriously and will be reviewed by an appropriate University official. Whenever possible, the resolution of any investigation will be conveyed to the caller. Under normal circumstances, the hotline will be checked for messages on a daily basis, Monday - Friday, excluding holidays.
There are alternate resources available on campus and off for potential compliance issues.
Binghamton University Ethics Officer Joseph Schultz, (607)777-2187 firstname.lastname@example.org
University Ombudsman (607)777-2388 or http://ombudsman.binghamton.edu
Human Resources (607-777-2108)
SUNY System Administration - Auditor (518-320-1539) or http://www.suny.edu/UniversityAuditor/reportFraud.cfm
Think Before You Speak
Please think before making allegations of fraud or dishonesty and be reasonably certain of any claims. Such allegations can significantly and negatively impact the life of the accused individual and adversely affect the working environment of the department.
Binghamton University Fraud-Related Policies
Management Procedure #209 - Reporting Theft, Loss or Misuse of State Asset(s)
Management Procedure #631- Fraud and Irregularities / Compliance Hotline Policy
SUNY System Report Fraud
SUNY Form A - Fraud Incident Report
Binghamton University RF Compliance
SUNY RF Compliance Hotline
Complaints or concerns may be filed anonymously through the RF Ethics Hotline online at https://sunyrf.ospreycompliancesuite.com/incidentmanager/IncidentReport or by calling: 877-463-2179
Related Information Links
SUNY Policy 6001, Conflict of Interest
New York State Public Officers Law §73, Business or professional activities by state officers and employees and party officers
New York State Public Officers Law §73a, Financial Disclosure
NYS Public Officers Law §74, Code of Ethics
New York State Labor Law § 740, Retaliatory personnel action by employers; prohibition (whistleblower protection)
New York State Civil Service Law § 75-b, Public Sector Whistleblower Law (whistleblower protection)