Applies to: Faculty (including part-time and visiting faculty), postdoctoral scholars, staff and students (including graduate/undergraduate student workers and graduate assistants or students in clinical program seeking licensure) 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: July 1, 2008
Last Revised: March 11, 2024
Last Reviewed: April 8, 2024
2. Policy Purpose
This Misappropriation of University Assets Policy describes University expectations for the protection of University assets from theft or unauthorized use, and every University faculty and staff’s obligation to report occurrences when they become aware of the matter.
3. Scope and Application
This policy applies to:
- all University of Southern California faculty and staff (including those subject to a collective bargaining agreements)
- student workers, while acting in the capacity of staff
In the event of a discrepancy between this policy and a collective bargaining agreement, the terms of the collective bargaining agreement will govern.
Student workers may also be subject to misappropriation policies in accordance with the Student Handbook.
4. Definitions
| Term | Definition |
| Assets | Cash, inventory, equipment, facilities, or other tangible or intangible property owned by the University or entrusted to the University for the purpose of carrying out University functions. |
| Misappropriation | Unauthorized use or taking of University Assets. Misappropriation includes but is not limited to, theft or embezzlement of Assets, utilization of fraud or deception to use Assets for personal benefit, or any other improper use of Assets for personal benefit. |
5. Policy Details
- It is the responsibility of every University faculty member and staff employee, regardless of rank or job title, to safeguard Assets,
- not to commit or attempt to commit Misappropriation of Assets, and
- to promptly report any suspected Misappropriation of Assets.
Decisions by employees, which pose a conflict or the appearance of a conflict between the employees’ interest and the University’s interest, as described in the University’s Conflict of Interest policy, will be resolved by the Office of Culture, Ethics and Compliance.
6. Procedures
6.1 Reporting
Unless reporting anonymously, all University faculty and staff must report known or suspected Misappropriations to their immediate supervisor, manager, department chair or dean. Suspected Misappropriations may also be reported (anonymously if preferred) at the Report & Response website or by calling 213-740-2500.
Supervisors, managers, department chairs or deans who receive a report of known or suspected Misappropriation must immediately inform the Office of Audit Services.
Failure of a University employee to report known or suspected Misappropriations may be cause for disciplinary action up to and including termination.
6.2 Resolution and Investigation
The Office of Audit Services is responsible for resolving all reports involving the Misappropriation of Assets. The Office of Audit Services may, at its discretion, or at the direction of a Senior Vice President, conduct an investigation into the alleged Misappropriation. The Office of Audit Services may also refer such matters to another department, such as the Office of Culture, Ethics and Compliance, as it deems appropriate. Even if a matter is referred, the Office of Audit Services retains the responsibility for ensuring that these matters are investigated, reported on, or otherwise resolved.
When an investigation is conducted, the investigation may be performed internally or by independent accounting firms or other outside consultants to:
- Make factual findings on whether a Misappropriation occurred or was attempted, and/or is likely to occur;
- attempt to identify the person or persons responsible for the Misappropriation;
- reach a conclusion whether a faculty or staff violated this policy;
- determine the dollar amount of the alleged loss; and
- make departmental control recommendations to prevent future loss.
Before reaching findings and conclusions that a faculty or staff has violated this policy, the individual will be provided the opportunity to respond and present their side.
No department or individual should investigate Misappropriation on their own, or enter into any kind of discussion regarding settlement or restitution, without prior written approval from the Office of Audit Services as well as the Office of the General Counsel.
The Office of Audit Services may also review internal procedures and controls, and recommend to the appropriate senior administrator changes to those procedures and controls to limit further losses.
6.3 Findings and Resultant Actions
A final report of factual findings, and conclusion whether this policy has been violated, will be issued by the Office of Audit Services or its delegate. Any investigation report substantiating that a Misappropriation of University assets has occurred or was attempted must be forwarded to the Office of the General Counsel. Investigation reports prepared by other departments must be forwarded both to the Office of Audit Services and the Office of General Counsel.
If there is a conclusion that a faculty has violated this policy, the final report of that conclusion and the factual findings will be forwarded to the Committee on Professional Responsibility to determine sanctions and corrective actions as provide in the Faculty Handbook, and also forwarded to the relevant dean and to the Provost. If there is a conclusion that a staff member has violated this policy, a final report of that conclusion and factual findings will be forwarded to Human Resources to determine sanctions and corrective actions.
If there is a conclusion that a staff has violated this policy, the Senior Vice President of Human Resources or delegate, after reviewing the final report of findings, will prescribe the actions for non-faculty staff employees and will notify both the applicable department and the non-faculty employee of the prescribed disciplinary action. A non-faculty staff employee may file a written appeal with the Office of the Senior Vice President of Human Resources within 10 business days of their receipt of notice of the disciplinary action. The Senior Vice President of Human Resources, or delegate, will respond to the employee’s appeal within 30 days.
The University may seek criminal prosecution for any Misappropriation of Assets. Restitution from the person(s) committing the Misappropriation may be pursued, either on a voluntary basis or as the result of criminal prosecution or civil action.
If appropriate, the Office of Risk Management will coordinate the submission of an insurance claim with other involved departments and individuals.
6.4 Implementation
Departments, with assistance from their HR Partners, are required to implement the prescribed disciplinary action and to follow the recommendations put forth by the Office of Audit Services to improve departmental controls for preventing future losses. The Office of Audit Services will conduct a follow-up review to ensure the recommended action has been taken.
7. Forms
N/A
8. Responsibilities
| POSITION or OFFICE | RESPONSIBILITIES |
| Audit Services | Responsible for resolving all reports involving the Misappropriation of Assets and conducting follow-up |
| Senior Vice President Human Resources | Will prescribe and notify the department of actions for non-faculty employees |
| Senior Vice President Administration | Will respond to an employee disciplinary action appeal |
| Risk Management | Will coordinate submission of an insurance claim |
9. Related Information
Conflict of Interest and Commitment Policy
10. Contacts
Please direct any questions regarding this policy to:
| Alina Flamenco, Audit Services 1149 S. Hill Street, H375 Los Angeles, CA 90015 | 213-590-9311 | aflamenc@usc.edu |