Reporting Financial Irregularities Policy

Policy Summary

The George Washington University ("GW" or "university") must safeguard its financial assets from theft and misappropriation. Known or suspected financial irregularities must be immediately identified, reported, and investigated in order to reduce the university’s risk of financial losses and negative publicity. All members of the GW community are responsible for reporting known or suspected financial irregularities to the Office of Ethics, Compliance, and Risk. 

Financial irregularities and misappropriations of funds may result in criminal charges being brought against the responsible individual(s). If external funds are involved, the university may be responsible for the repayment of funds as well as any fines and penalties associated with the illegal activity. 

This policy establishes a central collection point for reporting all known or suspected financial irregularities so that financial and system controls can be thoroughly and consistently reviewed, evaluated, and modified in order to prevent similar irregularities in the future. 

Who is Governed by this Policy 

• Faculty
• Staff
• Students

Policy

Reporting and Investigating a Financial Irregularity 

When an instance of suspected or documented Financial Irregularity is uncovered by any member of the university community, it must be immediately reported to the appropriate department head who will then notify the Office of Ethics, Compliance, and Risk. Alternatively, the person who uncovers the alleged irregularity may choose to report their suspicions directly to the university’s Office of Ethics, Compliance, and Risk (202-994-3386, [email protected]) or anonymously using the EthicsPoint Reporting Form or via the phone at 1-888-508-5275, 24 hours a day, toll-free. The individual reporting the suspicious activity and/or department head must take no action to resolve the irregularity before consulting the Office of Ethics, Compliance, and Risk. The Office of Ethics, Compliance, and Risk will notify the appropriate individuals who will undertake the investigation.

The university investigates all allegations; the manner and process are dependent on the nature and subject of the allegation. Reports and investigations of Financial Irregularities are handled in a confidential manner until a determination is made on the university’s course of action. After this determination, the university reserves the right to make disclosures as necessary. Only the university’s Office of the Vice President and General Counsel may determine that a matter is to be referred to a law enforcement agency.

The Associate Vice President of Ethics, Compliance, and Risk will determine that each matter is being adequately investigated and resolved. If there is sufficient evidence of wrongdoing, the Associate Vice President of Ethics, Compliance, and Risk will communicate the findings internally to the Executive Vice President & Treasurer, the Vice President and General Counsel, and the Finance and Audit Committee of the Board of Trustees.

Definitions

Financial Irregularity: An intentional misstatement or omission of information related to financial transactions. Includes embezzlement, fraud, misuse of university assets, misappropriations of assets, falsification of records, or noncompliance with laws or regulations. 

Related Information

• Code of Ethical Conduct 
• Policy on Outside Interests, Relationships, and Professional Activities
• Financial Management Responsibility Policy 
• Non-Retaliation Policy

Contacts