Chapman University's Memorial Hall
Institutional Compliance

» Fraudulent Activities Policy


Chapman University is committed to upholding the highest standards of honest behavior, ethical conduct and fiduciary responsibility with respect to university funds, resources and property. All members of the Chapman community, including all those who do business with the university, are expected to uphold this policy.  Violation of this policy will result in appropriate disciplinary action, up to and including dismissal from or other severance of the relations with the university.



The University must identify and promptly investigate all instances and allegation of fraudulent activities regarding University funds, resources and property involving staff, faculty, students, vendors, agencies, or other parties. We believe that it is everyone's responsibility to report any possible fraudulent activity.



Fraud generally involves a willful or deliberate act with the intention of obtaining an unauthorized benefit, such as money or property, by deception or other unethical means.  All fraudulent acts are included under this policy and includes such things as:

  • Embezzlement, misappropriation or other financial irregularities
  • Bribery, extortion, unlawful rebates, kickback, and quid pro quo exchanges
  • Forgery or altercations of documents (checks, timesheets, contractor agreements, purchase order, other financial documents, electronic files)
  • Unauthorized disclosure of student educational records, private personnel records, medical information, or the proprietary information of the university
  • Improprieties in the handling or reporting of money or financial transactions
  • Theft of university information, property, records or assets
  • Misappropriation of funds, securities, supplies, inventory or any other assets (including furniture, fixtures or equipment)
  • Authorizing or receiving payment for goods not received, services not performed, or for non-university related matters
  • Claiming or receiving reimbursement from the university for money not expended, or for moneys expended for non-university related matters
  • Authorizing or receiving payments for hours not worked
  • Other similar illegal, dishonest or fraudulent conduct.


Reporting Procedure

Chapman counts on its community to help identify, investigate, and address issues that arise, and Chapman is committed to ensuring that such issues are promptly and properly addressed.

If you become aware of any activity you feel violates policy or demonstrates a lack of ethics, you are obligated as a member of the Chapman Family to report it.  Employees are encouraged to bring concerns directly to their supervisor, Human Resources (HR), or other campus entities as appropriate.  The university requests that a complaint be made in writing with a detailed description of the facts giving rise to the complaint, the names of any individuals involved, including any witnesses, and copies of any documents that support or relate to the complaint.

Any supervisor or manager who receives a complaint of fraudulent activity, or is otherwise aware of an incident of fraudulent activity, is required to promptly inform the Office of Institutional Compliance or one of the university vice presidents.  Knowingly withholding any such information is considered a serious breach of responsibility and may result in disciplinary action, up to and including termination from employment.

Further, you can anonymously and confidentially report any issue online via EthicsPoint.

Additional resources regarding compliance and reporting can be found on our Institutional Compliance page.


Retaliation Prohibited

The university prohibits and does not tolerate retaliation against any individual who files a complaint of illegal, dishonest or fraudulent conduct; is involved as a witness or participant in the complaint or investigation process; or refuses to engage in illegal, dishonest or fraudulent conduct.  Engaging in unlawful retaliation can result in disciplinary action, up to and including dismissal from the university.  An individual who files a complaint that the individual knows or believes to be false is not protected by this provision against retaliation and may be subject to disciplinary action up to and including dismissal from the university.



Name of Office: Institutional Compliance

Contact information for questions about this policy: Gail Nishida, Chief Compliance Officer,





Senior Staff member submitting the policy: Harold Hewitt

Date approved: August 13, 2019





Effective: August 13, 2019

Revision history: August 29, 2018



Code of Ethics Policy

Reporting Misconduct Policy

EthicsPoint Helpline

Whistleblower Policy