Applies to: This policy applies to all University of Southern California faculty and staff
1. Policy
Issued: 12/15/2011
Last Revised: 12/15/2011
Last Reviewed: 2/4/2022
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 provide insight as to how complaints will be 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 and Compliance 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 and Compliance 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
In order to adhere to the highest standards of integrity, the university encourages faculty members and staff employees to submit complaints regarding Accounting Matters. Such complaints may be submitted on a confidential and anonymous basis, if desired.
6. Procedures
6.1 Reporting
Any University faculty members or staff employees 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 USC Help and Hotline at (213) 740-2500, (800) 348-7454 or online at ethicspoint.com.
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 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).
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.
6.3 Findings and Resultant Actions
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.
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
N/A
10. Contacts
Please direct any questions regarding this policy to:
| OFFICE | PHONE | |
| Kiko Harvey, Audit Services | (323) 397-6943 | harveyk@usc.edu |