Original Issuance Date: December 12, 1974
Last Revision Date: March 22, 2022
1. Policy Purpose
This policy establishes the parameters for the reporting, investigation, and resolution of instances of fiscal misconduct within the University of Wisconsin System.
2. Responsible UW System Officer
Vice President for Finance
This policy applies to UW System employees and agents and covers instances of fiscal misconduct as defined in this policy.
The management, reporting, and resolution of financial conflicts of interest is governed by Wis. Admin. Code § UWS 8.04 (2016), Wis. Admin. Code § UWS 8.05 (2016) and Regent Policy Document 20-22, Code of Ethics.
The UW System is committed to the highest standards of financial stewardship and encourages the detection and prevention of acts that would be detrimental to this responsibility. Fiscal misconduct can occur in any organization including the UW System and its institutions. These acts carry legal implications for the university employee, both as an employee and as a citizen, and increase the risk to the operations and reputation of the UW System. This policy and UW System Administrative Procedure 304.A, Fiscal Misconduct: Reporting and Review Process establish expectations of employees and agents when managing or using the UW System’s fiscal resources and the reporting and review process to be used when suspected or actual fiscal misconduct has occurred.
Agent: Students and volunteers who have been authorized to act on behalf of the UW System or one of its institutions.
Employee: Faculty, staff, or students who work for the university in exchange for remuneration.
Fiscal Misconduct: A deliberate act or failure to act that is contrary to established laws, regulations or policies and which results or was intended to result in either loss or other damage to the State or the UW System or improper personal gain. Instances of fiscal misconduct to be reported and reviewed include, but are not limited to:
- Theft of any State or UW System funds or resources;
- Bribery, kickbacks, and bid rigging;
- Misappropriation, misapplication, destruction, removal, or concealment of State or UW System funds or resources;
- Authorizing or receiving compensation for hours not worked or covered by appropriate and available leave;
- Improper handling or reporting of financial transactions;
- Credit card and travel expense fraud; and
- Forgery, falsification, or unauthorized alteration of financial documents or records.
6. Policy Statement
When managing or using the university’s fiscal resources, employees, and agents of the UW System are expected to:
- act in accordance with all applicable laws, regulations, and policies with respect to the handling of State or UW System funds or resources;
- aid in the detection and prevention of fiscal misconduct;
- be familiar with the types of fiscal misconduct that could occur in their area;
- be attentive for suspected instances where fiscal misconduct might exist in their unit; and
- promptly report any known or suspected fiscal misconduct.
The course of action to be followed when reporting and investigating actual or suspected cases of fiscal misconduct is outlined in UW System Administrative Procedure (SYS) 304.A, Fiscal Misconduct: Reporting and Review Process. If an employee or agent of the UW System is found, or suspected, to be engaged in fiscal misconduct, the individual’s supervisor cannot solely determine the remedy to be used. Instances of fiscal misconduct are to be handled through the procedure outlined in SYS 304.A.
UW System employees who report an actual or suspected instance of fiscal misconduct in good faith shall not be subject to any adverse employment action including separation, demotion, suspension, or loss of benefits because of the report.
Reports and investigations will be kept confidential to the extent possible, consistent with UW policies, applicable laws, and the need for an investigation.
7. Related Documents
8. Policy History
Revision 5: March 22, 2022
Revision 4: April 28, 2017
Revision 3: January 22, 1998
Revision 2: November 5, 1993
Revision 1: October 14, 1983
First approved: December 12, 1974
9. Scheduled Review