December 15, 2011

Accounting and Auditing Complaint Reporting

In order to adhere to the highest standards of integrity, the university encourages employees to submit complaints regarding accounting, internal accounting controls, or auditing matters or concerns (“Accounting Matters”). Such complaints may be submitted on a confidential and anonymous basis, if desired.

Any employee with complaints or concerns regarding Accounting Matters may report them directly to the Associate Senior Vice President, Audit Services. Alternatively, employees may submit such reports anonymously via the Office of Compliance Help and Hotline at (213) 740-2500.

The university will not discharge, demote, suspend, threaten, harass, retaliate against, or in any other manner discriminate against an employee in the terms and conditions of employment based upon any lawful actions of such employee with respect to his/her good faith reporting of complaints and concerns regarding Accounting Matters.

All complaints and concerns regarding Accounting Matters that are received by the university will be reviewed under the oversight of the Audit and Compliance Committee of the university’s Board of Trustees and directed to the Associate Senior Vice President, Audit Services, who will appropriately investigate all such reports. Audit Services will retain appropriate documentation of all such reports, and the course and results of all investigations (including all relevant information such as dates, times, places, sources, and nature of allegations).

Any allegation that the Associate Senior Vice President, Audit Services or any of his/her direct reports has been or is involved in any questionable behavior or wrongful acts with respect to Accounting Matters will be directed to the Senior Vice President for Administration who will (a) bring such report to the immediate attention of the chair of the Audit and Compliance Committee, and (b) promptly conduct an investigation and report the results to said committee.

All reports that could reasonably have a material effect on the university’s financial statements or that involve allegations which are credible on their face concerning a member of the Board of Trustees, senior administrator, or financial officer of the university will be brought to the immediate attention of the chair of the Audit and Compliance Committee, and results and conclusions of any related investigation will be reported to the committee as soon as practicable.

Except when this policy requires a more prompt report, the Associate Senior Vice President, Audit Services will report the results of all Audit Services investigations and all reports received pursuant to this policy to the Audit and Compliance Committee at its meetings.

The university, with the oversight of the Audit and Compliance Committee, will take prompt and appropriate corrective action based upon investigations related to this policy.

Responsible Office

Audit Services

(213) 740-8258

Issued by

Elizabeth Garrett, Provost and Senior Vice President, Academic Affairs
Todd R. Dickey, Senior Vice President, Administration
University of Southern California