Applies to: Faculty (including part-time and visiting faculty), postdoctoral scholars, and staff employed by the University of Southern California USC Health System, and their respective subsidiaries and affiliates in addition to volunteers (“USC employees”). This policy continues to apply to individuals on sabbatical, other leaves or while visiting other institutions.
1. Policy
Issued: December 15, 2011
Last Revised: March 18, 2024
Last Reviewed: April 2, 2024
2. Policy Purpose
To provide information to employees regarding the process for submitting complaints regarding accounting, internal accounting controls, or auditing matters or concerns (“Accounting Matters”) and to detail how complaints are handled by the appropriate parties once submitted.
3. Scope and Application
This policy applies to all complaints regarding Accounting Matters submitted to the University. All complaints regarding Accounting Matters will be investigated by the Associate Senior Vice President, Audit Services, under the oversight of the Audit, Compliance, Risk and Privacy Committee of the University’s Board of Trustees. 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, Compliance, Risk and Privacy Committee, and (b) promptly conduct an investigation and report the results to said committee.
4. Definitions
| Term | Definition |
| Accounting Matters | Accounting, internal accounting controls, or auditing matters or concerns. |
5. Policy Details
University faculty and staff may submit complaints or concerns regarding Accounting Matters. Complaints may be submitted anonymously at USC’S Report and Response website.
6. Procedures
6.1 Reporting
Any University faculty or staff with complaints or concerns regarding Accounting Matters may report them directly to the Associate Senior Vice President, Audit Services. Alternatively, faculty or staff may submit such reports (anonymously if preferred) at the Report & Response website or by calling 213-740-2500. All complaints, regardless of how initially reported, will be logged through the centralized complaint reporting database by the intake party.
6.2 Resolution and Investigation
All complaints and concerns regarding Accounting Matters that are received by the University will be reviewed under the oversight of the Audit, Compliance, Risk and Privacy 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).
All reports that could reasonably have a material effect on the University’s financial statements or that involve allegations concerning a member of the Board of Trustees, or senior administrator of the University will be brought to the immediate attention of the chair of the Audit, Compliance, Risk and Privacy Committee by the Associate Senior Vice President, Audit Services, and results and conclusions of any related investigation will be reported to the committee as soon as practicable.
6.3 Findings and Resultant Actions
Except when this policy requires a more immediate 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, Compliance, Risk and Privacy Committee at its meetings and the results of these reports once investigations conclude.
The University, with the oversight of the Audit, Compliance, Risk and Privacy Committee, will take prompt and appropriate corrective action based upon investigations related to this policy in the event the allegations are substantiated through investigation.
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.
7. Forms
N/A
8. Responsibilities
| POSITION or OFFICE | RESPONSIBILITIES |
| Audit and Compliance Committee | Direct and oversee the Associate Senior Vice President, Audit Services, or the appropriate party, with regards to performing the investigation. |
| Associate Senior Vice President, Audit Services | Perform investigations of complaints regarding Accounting Matters and report results of investigations and all reports received to the Audit and Compliance Committee. |
| Senior Vice President for Administration | 1. Perform the investigation of the complaint(s) regarding Accounting Matters if made regarding the Associate Senior Vice President, Audit Services, or any of his/her direct reports. 2. Report results of investigations and all reports received to the Audit and Compliance Committee. |
9. Related Information
10. Contacts
Please direct any questions regarding this policy to:
| OFFICE | PHONE | |
| Kiko Harvey, Associate SVP, Audit Services | (323) 397-6943 | harveyk@usc.edu |