Rancho Santiago Community College District (the District) supports a culture of ethical behavior and accountability wherein employees are encouraged to report their suspicions of fraud or waste of District resources without fear of reprisal.
The District retains the services of ComplianceLine, Inc. (dba Ethico) for intake of fraud reports. ComplianceLine, Inc. is an independent third party provider that operates 24 hours a day 7 days a week. By using an independent third party, the District provides individuals a means to report suspicions of fraud anonymously. After submitting a report, reporters will be given a unique report code that can be used to check the status of the report.
Once the complaint is reported, ComplianceLine, Inc. makes the report available to the following individuals at the District:
- Director of Accounting, Audit & Advisory Services
- Audit Specialist
- Vice Chancellor, Business Services
- Assistant Vice Chancellor, Fiscal Services
- Vice Chancellor, Human Resources
- Assistant Vice Chancellor, Human Resources
All reports are evaluated and may result in an inquiry or investigation. An appropriate investigator is assigned based on the nature of the report. If the complaint is about one of the individuals listed above, that individual would not receive the report. During an inquiry or investigation, the parties most directly connected may be notified of the matter and asked to assist with the inquiry or investigation. This may include the immediate supervisor of the parties involved and any individuals who can provide any relevant information concerning the matter under evaluation.
The following situations are potential indicators with a higher risk of fraud:
- Inadequate internal controls over assets, lack of segregation of duties or independent checks, especially in areas such as purchasing, accounts payable, cash handling, payroll, and inventory.
- Lack of management oversight.
- Inadequate physical safeguards over cash, investments, inventory, or fixed assets.
- Frequent or no vacations are taken by employees performing key controls.
- Conflicts of interest.
- Changes in behavior or lifestyle that may indicate misappropriation of District assets.
- Management override of internal controls.
- Fraudulent reporting of student or employee information.
The following are some examples of fraudulent activity and waste of District resources that could occur at a community college:
- Utilizing funds (including Trust, Agency, and Foundation funds) for personal gain/benefit
- Utilizing funds (including Trust, Agency, and Foundation funds) on unnecessary expenses in order to spend funds down
- Utilizing funds (including Trust, Agency, and Foundation funds) in a manner that is not reasonable and necessary
- Decision-maker procuring from family/friends above market price for goods or services
- Decision-maker accepting gifts from a vendor prior to or after issuing a contract
- Theft of cash on hand, cash received, gift cards, or benefit cards
- Theft or misuse of inventory, supplies, or fixed assets
- Fraudulent payments to vendors or employees
- Invoice kickbacks
- Charging personal expenses to a District-issued credit card
- Submitting fictitious expense reimbursements or expense reimbursements for expenses already paid
- Fictitious or understated revenues
- Concealed or overstated liabilities and expenses
- Awarding financial aid to ineligible students
How to Report Suspicion of Fraud
If you suspect that fraud has or is potentially occurring, report by:
Calling the District's third party fraud hotline at 877-235-3224
OR
Accessing the online webform at https://www.mycompliancereport.com/report?cid=RSCCD
and enter Company Code: RSCCD.
Providing specific details helps facilitate a thorough evaluation of the concern. Before calling the fraud hotline or completing the online webform, please ensure you have the following information to the extent it is available to provide:
- When (or approximately when) the incident occurred.
- Who was involved, witnesses and other individuals who may be aware of the incident. Names and positions are helpful.
- Where the alleged incident occurred.
- What the alleged incident is. A full description of events. Specific details as applicable such as GL account numbers, bank account numbers, dollar amounts, quantities, transaction reference numbers, the system(s) and relevant financial records or reports, etc.
- How the alleged incident was committed.
- Documented evidence if that can be provided.
No Retaliation Policy
The District's Board Policy and Administrative Regulation 7700 address Whistleblower Protection. The District encourages individuals to report suspected incidents of fraud without fear of retaliation. The District prohibits retaliation against employees who, in good faith, report fraud and/or assist the District in its investigation. Under Administrative Regulation 7700, retaliation against such employees is subject to disciplinary action up to and including termination of employment. The District is not precluded from taking appropriate action where an individual knowingly asserts a false or embellished complaint or makes knowingly false statements.
Confidentiality Statement
The District can never guarantee that the information provided by an individual will remain confidential. Your identity may become known during the course of an inquiry or investigation. The District cannot share the specifics of an administrative determination where it relates to confidential information.