I. Policy Introduction
The University is committed to safeguarding assets that are its rightful property or responsibility and protecting such University assets from misappropriation and supports timely reporting of suspected fiscal irregularities.
II. To Whom This Policy Applies
This policy applies to trustees, officers, faculty, staff, postdoctoral scholars, student employees, students managing University funds, and third parties acting on behalf of the University. It applies to all University resources, including operating funds, sponsored research, gifts, endowment of assets, and affiliated or controlled entities.
III. Policy Principles
The University is committed to the highest standards of integrity, transparency, and accountability in the stewardship of its fiscal resources. As a private, nonprofit institution, the University has fiduciary obligations to its Board of Trustees, donors, sponsors, partners, students, accrediting bodies, and the broader public trust.
This policy exists to assist all members of the University community in recognizing fiscal misconduct and to encourage individuals to report known or suspected fiscal misconduct. This policy is designed to provide a coordinated approach for review and resolution.
Syracuse University expects all members of the University community to uphold the highest ethical standards in all fiscal transactions and in the reporting of fiscal information. Each member of the community shares a responsibility to exercise due care, sound judgment, and integrity in the use and stewardship of the University assets. The University takes this stewardship seriously, as it does any allegation of fiscal wrongdoing.
This policy establishes the procedures for reporting and investigating actual or suspected fiscal irregularities. Syracuse University values and respects the rights, dignity, and confidentiality of all members of the University community, including individuals who may be accused or suspected of involvement in fiscal irregularity. Accordingly, all reports and investigations will be conducted with independence, objectivity, and appropriate confidentiality.
The University recognizes that matters initially perceived as potential fraud may, upon review, be the result of unintentional errors rather than deliberate misconduct such as embezzlement, fraud, or misappropriation. For this reason, care, discretion, and diligence are essential in responding to and investigating suspected fiscal irregularities. Syracuse University also supports the establishment and maintenance of effective internal controls to help prevent and detect fiscal irregularities. Management is responsible for identifying and managing fiscal risks, as well as for the development, monitoring, and ongoing maintenance of these controls.
A. Fiscal Misconduct
Fiscal misconduct threatens the University’s mission, stewardship responsibilities, and reputation. The University will not tolerate fiscal misconduct and will take prompt, appropriate action when such conduct is suspected or confirmed.
In the context of this policy, fiscal misconduct means a deliberate act or failure to act in the course of University employment regarding fiscal matters, contrary to established law, rule, or policy, with the intent to obtain an unauthorized benefit, which results in loss or other damage to the University or University faculty, staff, student or University affiliated entity. A failure to act includes, but is not limited to, a failure to meet the standards of conduct described in Section C (Standards of Conduct and Prevention).
Examples of Fraud and Fiscal misconduct include, but are not limited to:
- Embezzlement, theft, or misappropriation of University funds, goods, property, services, systems, or other resources.
- Forgery or unauthorized alteration of fiscal documents or records.
- Improper handling or reporting of fiscal transactions.
- Intentional disregard for University fiscal policy and procedure.
- Authorizing or receiving the following:
- Compensation for goods not received or services not performed.
- Compensation for hours not worked, including falsifying timesheets or other payroll records.
- Reimbursement for expenses not incurred or reimbursement for expenses not incurred for University purposes.
The University maintains internal controls to protect against loss or other harm related to fiscal misconduct. Maintaining this environment is a shared responsibility, and employees are encouraged to report any concerns they may observe.
Fiscal misconduct is distinct from honest mistakes and inadvertent errors. While such errors must be corrected, they do not constitute misconduct under this policy unless they involve gross negligence or a pattern of repeated failures indicating disregard for fiscal management obligations
B. Prohibited Conduct
The following conduct is expressly prohibited. This list is illustrative and not exhaustive. Prohibited conduct includes: (1) theft, embezzlement, misappropriation, or unauthorized use of University funds, property, equipment, or other assets; (2) forgery, falsification, alteration, or unauthorized destruction of fiscal records, contracts, invoices, timesheets, expense reports, or other University documents; (3) misuse or unauthorized use of University procurement cards, purchasing authority, or vendor relationships; (4) deliberate circumvention of or interference with University fiscal controls, approval workflows, or audit processes; (5) improper use of restricted, sponsored, or gift funds in a manner inconsistent with donor intent, grant terms, or legal requirements; (6) offering, soliciting, or accepting bribes, kickbacks, or other improper personal benefits in connection with University business; (7) intentional concealment of known or suspected fiscal misconduct by any member of the University community; and (8) retaliation or threatened retaliation against any person who reports suspected fiscal misconduct in good faith or who cooperates in an investigation.
C. Standards of Conduct and Prevention
All individuals covered by this policy are expected to: (a) act with honesty, integrity, and due professional care in all fiscal matters; (b) safeguard and use University assets solely for authorized purposes; (c) comply with all applicable University policies, procedures, and legal or regulatory requirements; (d) actively support the University’s system of internal controls and refrain from any action that would undermine, circumvent, or disable those controls; (e) complete required fiscal training and certifications in a timely manner; (f) promptly disclose actual or potential conflicts of interest that could affect fiscal decision-making; and (g) promptly report known or suspected violations of this policy through appropriate channels. Units and departments are also expected to maintain accurate and complete fiscal records and to cooperate fully with internal audit, compliance reviews, and any investigation conducted pursuant to this policy.
D. Roles and Responsibilities
Employees- All employees are responsible for preserving the University resources entrusted to them and for using those resources in a prudent manner and for their designated purposes. Employees are also responsible for promptly reporting incidents of suspected fiscal misconduct, whether by members of the University community or by outside parties. Employees are expected to cooperate fully with those authorized to conduct the investigation.
Managers and Supervisors- Employees with managerial or supervisory duties are responsible for creating an environment that contributes to the deterrence of fiscal misconduct and for maintaining a system of internal controls that assists in the prevention and detection of incidents of misconduct. Managers and supervisors should be familiar with the types of fiscal misconduct that might occur within their area of responsibility and be alert for indications of their occurrence.
The Office of Compliance – This Office is responsible for tracking complaints submitted through the University’s confidential reporting hotline. Fiscal reports submitted through this system are triaged to the appropriate office(s) for investigation with a copy to the Office of University Counsel.
The Office of the Comptroller – This Office will aid with initial assessment of potential claims as well as serve as a resource for campus regarding education of internal control activities and the University’s internal control environment.
The Office of University Counsel- will serve as the liaison with external legal entities and will coordinate the reporting of criminal actions to the respective authorities.
The Office of Institutional Risk and Audit Services – This Office has the responsibility for coordinating formalized reviews and investigations when asked to do so by the Chief Financial Officer.
E. Reporting Fiscal Misconduct
Suspected fiscal misconduct should be reported promptly through the Ethics Point confidential reporting hotline. A link to the reporting line can be found in section VII of this policy. Individuals should not conduct their own investigations. Some allegations may quickly be determined to be unfounded or resolved in a short amount of time, while others may require detailed investigation and may result in referral to appropriate law enforcement authorities for legal prosecution.
F. Confidentiality and non-retaliation
Reporting suspected fiscal misconduct is a service to the University, and an individual making a good faith report of fiscal misconduct to a supervisor, Ethics Point, or another University employee will not be subject to any form of retaliation for making such a report. While all allegations will be reviewed based on the information that is available, disclosure of the reporting person’s identity provides greater credibility to the report and can assist in the successful completion of an investigation. If a reporting person feels compelled to report anonymously, the report should contain enough facts to facilitate a meaningful investigation. All investigations will be conducted confidentially, and sources of information will be held in confidence, to the extent possible. It is the University’s policy to report criminal fraudulent activities to the appropriate law enforcement authorities for prosecution. In these circumstances, it may not be possible for the University to maintain confidentiality.
G. Investigation Process
Upon receipt of a report of suspected fiscal misconduct through the University confidential reporting hotline, the Office of Compliance will triage the report to the appropriate office for investigation. Full investigations will be conducted by trained impartial personnel, typically from the Office of Human Resources, the Office of the Comptroller, the Office of General Counsel as well as formalized reviews by the Office of Institutional Risk and Audit services as appropriate. If warranted external resources could be utilized to assist with the reviews.
Investigations will be documented, including the allegations made, evidence gathered, interviews conducted, and findings reached. The subject of an investigation will be provided with an opportunity to respond to relevant findings prior to a final determination, consistent with applicable University policies and any collective bargaining agreements. Investigation timelines will be reasonable and proportionate to the complexity of the matter. A written report summarizing findings and recommendations will be prepared at the conclusion of each full investigation and provided appropriate senior leadership.
Digital preservation is required during an investigation. This can include things such as email holds, access logs from fiscal systems, and preservation of relevant audit trails. The Office of Information Technology Services may need to be contacted for assistance.
H. Corrective and Disciplinary Action
When an investigation confirms a violation of this policy, the University will take prompt and proportionate corrective action. Corrective action may include one or more of the following, depending on the nature, severity, and circumstances of the misconduct: (a) written reprimand or formal warning; (b) required training or remediation; (c) suspension with or without pay; (d) termination of employment or academic appointment; (e) termination of a vendor, contractor, or other third-party relationship; (f) civil recovery or restitution of misappropriated funds or assets; (g) referral to appropriate law enforcement or regulatory authorities for potential civil or criminal prosecution; and (h) debarment from future University contracts or appointments. Corrective actions involving employees will be administered in accordance with applicable University human resources policies, faculty governance procedures, and any applicable collective bargaining agreements. Corrective actions will be documented and retained in accordance with the University Records Retention Schedule. The University reserves the right to pursue all available legal remedies in cases of confirmed fiscal misconduct.
I. Governance and Oversight
Oversight of this policy resides with the Offices of the Chief Financial Officer and the Office of General Counsel.
IV. Responsibilities
The Office of the Chief Financial Officer will periodically review the policy.
V. Record Retention
Records associated with the policy shall be maintained by the Responsible Office and retained or disposed of in accordance with University Records Policy and University Record Retention Schedule.
VI. Compliance
The Office of Institutional Risk and Audit Services, the Office of Compliance, the Comptroller’s Office, the Responsible Office, and others may audit, investigate, and assess compliance with this policy. Non-compliance with University policies is subject to progressive disciplinary action up to and including termination per University disciplinary policies.
VII. Related University Policies and Resources
| Web Link | Description |
| University Bylaws | Syracuse University Bylaws; |
| Code of Ethics | Code of Ethical Conduct; |
| Board of Trustees Conflict of Interest | Board of Trustees Conflicts of Interest; |
| Conflict of Interest for faculty-and-staff | Conflict of Interest and Commitment for Faculty and Staff; |
| Conflict of Interest or Principal Investigators and Senior Personnel on Sponsored Programs | Conflict of Interest and Commitment for Principal Investigators and Senior Personnel on Sponsored Programs |
| Outside Professional Consulting by Non-Faculty or Employees | Outside Professional Consulting by Non-Faculty or Employees; |
| Faculty Manual | Faculty Manual; |
| Ethics Point | Ethics Reporting Hotline |
VIII. Definitions
| Term | Definition |
| Abuse or Waste
|
Improper or excessive use of University resources is inconsistent with prudent business practices or donors or sponsor intent.
|
| Embezzlement | An intentional act in which one person fraudulently converts to one’s own use of another person’s or entity’s money or property. |
| Falsification of Records | An intentional act to falsify, alter, destroy, or tamper with University records for the purpose of committing or concealing wrongdoing or deceiving. |
| Fiscal Misconduct | Any intentional, reckless, or grossly negligent act or omission that results in unauthorized fiscal benefit or harm to the University. |
| Fraud | Intentional deception or misrepresentation to secure improper benefit or cause loss. |
| Management | Deans, directors, department chairs, and other individuals with administrative or supervisory authority over a University department, unit, or program. |
| Misappropriation | The unauthorized, improper, or unlawful use of funds or other assets/property for purposes other than that for which it is intended. |
IX. Policy Administration and Responsible Office
| Contact | Phone Number | Email/web address |
| Jean Gallipeau | 315-443-3765 | jbgallip@syr.edu |
| Kelly Flannery | 315-443-5771 | kmflanne@syr.edu |
X. Responsible Executive
Chief Financial Officer
XI. Revision History
July 1, 2026 – Original Issue