Fraud Policy

Ref. No.	Executive sponsor	Policy steward	Approval authority	First approved	Last reviewed	Effective date	Next review
76.21	Vice President, College Services and Strategy	Chief Financial Officer	Board of Governors	Dec. 14, 2017	Oct. 20, 2022	Oct. 21, 2022	Oct. 2027

Purpose
1. NSCC takes our responsibility and accountability for the public’s trust seriously. Dishonesty and fraud will not be tolerated and often leads to litigation, dismissal, and recovery of assets..
2. The purpose of this policy is to:
  1. Clearly define fraudulent activity.
  2. Provide guidance for employees.
  3. Create an added measure of fraud protection for assets.

Scope
1. The policy applies to all employees.

Definitions

Term	Definition
Employee	An individual who is currently employed with NSCC to perform work for the College. This includes all employees, regardless of status, as well as current employees who are on a leave of absence (paid/unpaid).
Fraud	The Institute of Internal Auditors refers to fraud as any illegal acts characterized by deceit, concealment or violation of trust. These acts are not dependent upon the threat of violence or physical force. Frauds are perpetrated by parties and organizations to obtain money, property or services; to avoid payment or loss of services; or to secure personal or business advantage.

Policy
1. Commitment
  NSCC is committed to:
  1. Applying this policy equally to all employees regardless of their position, past performance, or length of service with the college.
  2. Maintaining an environment that prevents fraud by using well established internal controls.
  3. Providing a safe environment for disclosing fraud as outlined in our Safe Disclosure Policy.
  4. Fully investigating allegations or suspected instances of potential fraud.
  5. Taking all reasonable means, including legal action, to recover losses.
  6. Maintaining confidentiality through the investigative process.
2. Roles and Responsibilities
  1. Employees
    1. Report any instance of suspected irregularities immediately to their supervisor and/or the Director of Internal Audit.
    2. Provide complete cooperation with fraud investigations.
  2. Managers
    1. Be familiar with the risks and indicators of fraudulent activity specific to their department and/or Campus.
    2. Ensure employees are informed about the fraud policy.
  3. Director of Internal Audit
    1. Coordinate fraud investigations according to the Investigation guidelines in Appendix B.
    2. Report instances of fraud to the police when criminal charges may be warranted.
    3. Coordinate the written report of investigation results to be shared with the investigative team and the Executive Team.
    4. Review College policies and procedures after instances of fraudulent activity to reduce the possibility of a similar event recurring.
3. Investigation of Fraudulent Activities
  1. Allegations or suspected instances of fraud should be immediately brought to the attention of the Director of Internal Audit. The Director will be responsible for coordinating individuals from the appropriate College Departments to assist with the investigation. These individuals must thoroughly document all aspects of their involvement with the investigation. The Director of Internal Audit will contact the police in instances where criminal charges may be warranted.
  2. The Director of Internal Audit should consult with the President, the employee’s supervisor and a representative assigned by the Vice-President, Organizational Development as required, during the investigation process. This may require assembling a team to investigate the allegations or suspicions of fraud.
  3. The Vice-President, Organizational Development or a designated staff member will provide guidance if disciplinary action is required as a result of the investigation.
  4. The investigation must remain confidential although it’s expected that the investigators will share general information with applicable members of the senior management. Copies of the investigation report will have limited circulation.
  5. Individuals involved with the investigation process must remain unbiased.
  6. The results of the investigation must be included in a written report coordinated by the Director of Internal Audit. Limited copies of the report will be delivered to the investigation team with a copy to the President and Vice-Presidents.
  7. The individual suspected of fraudulent activities should not be confronted prior to the investigation process. Records related to the activity need to be seized before the suspected employee becomes aware of the investigation.
  8. An employee suspected of fraudulent activities maintains legal rights which must be respected.
  9. Investigation interviews should include at least two members of the investigative team. The team may choose to employ professional interrogators if the interrogation is expected to trigger significant exposure for the College.
  10. All reasonable means, including legal action, should be used to recover losses.
  11. Instances of fraudulent activity should be followed up with a review of the College’s policies and procedures. Management should make the changes that are required to reduce the possibility of a similar event recurring.

Policy Supports

Related Policies & Procedures

42.11 Conflict of Interest and Commitment Policy
42.31 Safe Disclosure Policy
62.01 Travel and Reimbursement Policy
62.05 Presidential Travel Expenses
62.11 Entertainment and Other Expenses
62.21 Procurement Policy

Appendix A: Examples of Fraud
1. Fraudulent activity could include, but is not limited to:
  1. An improper act to conceal the theft of College assets, to avoid payment or to obtain personal advantages at the cost of the College (e.g. forgery of College documents)
  2. Embezzlement of College assets
  3. Misappropriation or misuse of College assets
  4. Inaccurately reporting financial information for a personal advantage
  5. Certain types of unethical behaviour associated with someone who uses their position at the College for personal advantage to the detriment of the organization. Certain aspects of this behaviour are documented in the College’s Conflict of Interest Policy. For example, an employee might use students or staff on College time to carry out work for an enterprise in which either the employee or a person with a relationship to that employee has a financial or other interest.
  6. Authorizing or receiving remuneration for time not worked
  7. Authorizing or receiving remuneration for goods that were not received or services that were not performed.
  8. Computer crimes
  9. Covering up bribery

Appendix B: Guidelines for Investigation of Fraudulent Activities
1. Investigation Guidelines
  1. The Director of Internal Audit is responsible for coordinating individuals from the appropriate College Departments to assist with the investigation. These individuals must thoroughly document all aspects of their involvement with the investigation. The Director of Internal Audit will contact the police in instances where criminal charges may be warranted.
  2. The Director of Internal Audit should consult with the President, the employee’s supervisor and a representative assigned by the Vice-President, Equity, Strategy and People as required, during the investigation process. This may require assembling a team to investigate the allegations or suspicions of fraud.
  3. The Vice-President, Equity, Strategy and People or a designated staff member will provide guidance if disciplinary action is required as a result of the investigation.
  4. The investigation must remain confidential although it’s expected that the investigators will share general information with applicable members of the senior management. Copies of the investigation report will have limited circulation.
  5. Individuals involved with the investigation process must remain unbiased.
  6. The results of the investigation must be included in a written report coordinated by the Director of Internal Audit. Limited copies of the report will be delivered to the investigation team with a copy to the President and Vice-Presidents.
  7. The individual suspected of fraudulent activities should not be confronted prior to the investigation process. Records related to the activity need to be seized before the suspected employee becomes aware of the investigation.
  8. An employee suspected of fraudulent activities maintains legal rights which must be respected.
  9. Investigation interviews should include at least two members of the investigative team. The team may choose to employ professional interrogators if the interrogation is expected to trigger significant exposure for the College.
  10. All reasonable means, including legal action, should be used to recover losses.
  11. Instances of fraudulent activity should be followed up with a review of the College’s policies and procedures. Management should make the changes that are required to reduce the possibility of a similar event recurring.