Policies

Policies provide a framework by which employees are expected to behave in the workplace. These policies are written statements of the company's standards and objectives and include all areas of employment. They contain rules on how employees must perform their jobs and interact with each other. Managers, employees and the Office of Human Resources all have roles in ensuring that HR policies are effectively implemented.

Purpose

This policy is established to provide increased protection to the assets and financial interests of Chicago State University, to provide a coordinated approach to the identification, investigation and resolution of fraudulent activities, and to increase the overall awareness of the responsibility to report fraud and reasonably suspected fraudulent activity to the appropriate Chicago State administrators.

Scope

This policy applies to any situation of fraud or suspected fraud involving University employees, students, vendors, contractors, consultants, outside agencies, and/or any other parties with a business relationship with Chicago State University. Any investigative activity conducted will be done without regard to the suspected wrongdoer’s title/position, past performance, or length of service to the University.

Fraud Definition and Examples

For purposes of this policy, fraud includes any willful or deliberate act committed with the intention of obtaining an unauthorized benefit, such as money or property, by misrepresentation, deception, or other unethical means.

Fraud and financial impropriety may include, but are not limited to the following actions:

  • Embezzlement or other financial irregularities;
  • Forgery, alteration, or falsification of documents (including checks, time sheets, travel expense reports, contractor agreements, purchase orders, other financial documents, student academic or financial records, electronic files);
  • Misappropriation, misuse, theft, removal, or destruction of University resources (including funds, securities, supplies, inventory, furniture, fixtures, equipment, intellectual property or any other asset);
  • Improprieties in the handling or reporting of money or financial transactions;
  • Misuse of University facilities (including telephones, computers and e-mail system);
  • False claims by student, employees, vendors, or other associated with Chicago State University;
  • Receiving or offering bribes, rebates, or kickbacks;
  • Personal use of University property in commercial business activities;
  • Accepting or seeking anything of material value from contractors, vendors or persons providing or seeking to provide services/materials to the University (Except as permitted by the Illinois Gift Ban, 5 ILCS 430/10);
  • Conflict of interest;
  • Misrepresentation of facts;
  • Any similar or related irregularity

Responsibilities

Chicago State administrators at all levels of management are accountable for setting the appropriate tone of intolerance for fraudulent acts by displaying the proper attitude toward complying with laws, rules, regulations, and policies. Managing administrators are responsible for identifying and assessing the level of the risks and exposures to fraudulent activity inherent in his or her area of responsibility. Additionally, managing administrators shall establish and maintain proper internal controls which will provide for the security and accountability of the resources within his or her department. All University employees are responsible for safeguarding University resources and ensuring that they are used only for authorized purposes, in accordance with University rules, policies, and applicable law.

Fraud Indicators

The following, though non-exclusive, may indicate fraudulent financial activities:

  • Excessive number of missing or voided documents
  • Alterations of documents
  • Questionable handwriting or approval
  • Documents not numerically controlled
  • Duplicate payments
  • Unusual billing addresses or arrangements
  • Vendor’s billing address is the same as employee’s
  • Duplicate or photocopied invoices

Reporting Fraud

Employees, students, and other individuals associated with Chicago State (collectively, members of the University community) who become aware of, or have a reasonable basis for believing that fraud, defalcation, misappropriation or other fiscal irregularities has occurred shall promptly report the suspected activity to the Office of Internal Audit, University Police, or General Counsel/Ethics Officer. If the suspected fraudulent activity involves a member of the Internal Audit, University Police or General Counsel/Ethics Officer, the activity should be reported to the Chicago State University President.

Great care must be taken in dealing with suspected fraudulent activities so as to avoid any incorrect accusations, alerting suspected individuals that an investigation is under way, violating a person’s right to due process, or making statements that could lead to claims of false accusations or other civil rights violations. Any employee who suspects fraudulent activity shall report it to the Office of Internal Audit, University Police, or General Counsel/Ethics Officer and shall not attempt to personally conduct an investigation or interview individuals suspected of being involved in the suspected fraudulent activity.

Investigation

The Office of Internal Audit has the primary University office responsible for conducting investigations of fraud and suspected fraudulent activity reported to its office. Additionally, the Office of Internal Audit may identify and investigate any suspected dishonest or fraudulent activity, which in its opinion, may represent risk of significant loss of assets or reputation to the University. The Internal Auditor may work with internal or external departments, such as the University General Counsel’s office, Human Resources, Police and other law enforcement agencies, as circumstances may require.

In the event that the Office of Internal Audit determines that an investigation of suspected fraudulent activity is warranted, the Office will conduct the following procedural steps:

  • Notify the President and General Legal Counsel.
  • Advise management to meet with Human Resources Director to determine if any immediate disciplinary personnel actions should be taken.
  • Coordinate the notification of insures and filing of claims with the Risk Management Office. This office is responsible for notifying bonding companies and filing bonding claims.
  • If federal funds are involved, determine the required federal reporting in cooperation with the grantee department and University General Legal Counsel.
  • If illegal activity is indicated, notify the University Police to coordinate an investigation.
  • If illegal activity appears to have occurred, the findings will be reported to the appropriate agency for review such as the Illinois Attorney General. This will be coordinated with the University General Legal Counsel.
  • Notify the Office of the State of Auditor as required by FCIAA guidelines.

Investigation Reporting

The Office of Internal Audit will review and communicate the results of any investigation with responsible management administrators. It will make recommendations for improvement to the systems of internal control, as needed. The results of investigation will also be communicated to the President and Board of Trustees.

Office of Executive Inspector General

The Office of Executive Inspector General is an agency of the State of Illinois that has authority to receive and investigate allegations of fraud, waste, abuse, mismanagement, misconduct or other violations of the State Officials and Employees Ethics Act.

University Actions

Chicago State University will take appropriate disciplinary and legal action against any individual or entity who commits fraud against the University. Any employee or student who engages in fraudulent activity relative to Chicago State University will be subject to discipline, which may include, but is not limited to, discharge from employment, expulsion from the University and or criminal prosecution under appropriate State and federal laws.

Whistle Blower Protection

In accordance with the Whistle Blower Protection Act (5 ILCS 395 et seq.), any Chicago State employee who reasonably believes that fraudulent activity has been conducted by another employee and reasonably reports the activity will not be subjected to an adverse employment action as a result of reporting the activity.

Chicago State University Anti‐Bullying Policy

It is the policy of Chicago State University that no student, faculty or staff member should be subjected to bullying or harassing behavior by any other student, faculty or staff member. Furthermore, no person should engage in any act of reprisal or retaliation against a victim, witness or anyone with information about an act of bullying or harassing behavior.  

Definitions 

“Bullying or harassing behavior” is defined as any pattern of gestures or written, electronic or verbal communications, or any physical act or any threatening communication, or any act reasonably perceived as being motivated by any actual or perceived differentiating characteristic, that takes place on any property owned or controlled by Chicago State University, or during any activity in whatever place sponsored by, directed or controlled by CSU, and that also fulfills one of the following conditions:  

  • Places a student, faculty or staff member in actual and reasonable fear of harm to his or her person or damage to his or her property  
  • Creates or is certain to create a hostile environment by substantially interfering with or impairing a student’s educational performance, opportunities or benefits  

“Hostile environment” is defined as the condition wherein the victim subjectively views the conduct as bullying or harassing behavior and the conduct is objectively severe or pervasive enough that a reasonable person would agree it is bullying or harassing behavior.  

“Suitable party” is defined as a person with responsibility to prevent bullying or harassing behavior within or during a particular activity, class, building or function. In the case of a student being subjected to bullying or harassing behavior, a suitable party might be an instructor, residence hall staff or a counselor. In the case of a faculty or staff member being subjected to bullying or harassing behavior, a suitable party might be a dean, academic chair or a superior.  

Employee/Student/Volunteer

As an employee/student/volunteer, I understand that in the course of my work for Chicago State University ("University"), I may have access to confidential, proprietary or personal information regarding faculty, staff, students, parents, alumni, vendors, the University and/or any minor enrolled in a University program. such confidential information may be verbal, on paper, contained in software, visible on screen displays, in computer readable form, or otherwise, and may include, but is not limited to, medical/health, financial, employment, contractual, or institutional data.

I hereby affirm that I will not in any way access, use, remove, disclose, copy, release, sell, loan, alter or destroy any confidential information except as authorized within the scope of my duties with Chicago State University. As an employee/student/volunteer, I must comply with applicable local, state and federal laws and University policies. I have a duty to safeguard and retain the confidentiality of all confidential information. Upon termination of my affiliation with Chicago State University, or earlier as instructed by the University, I will return to the University all copies of all materials containing confidential information.

I understand that I will be held responsible for my misuse or unauthorized disclosure of confidential information, including the failure to safeguard my information access codes or devices. My obligations under this Agreement are effective as of this day and will continue after my affiliation with Chicago State University concludes. Violation of these rules will result in discipline, which may include, but is not limited to, discharge from employment, expulsion from the University and or criminal prosecution under appropriate state and federal laws.

 

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This policy is being distributed to all Chicago State University employees and students in compliance with the provisions of the Drug-Free Workplace Act of 1988 (41 U.S.C., Section 701, et.seq.) and the Drug-Free Schools Act of 1989 (34 C.F.R. 86, et seq.).

Individuals Covered by this Policy

This policy applies to all employees (including hourly) who work on the Chicago State University Campus and in workplaces controlled by Chicago State University, and all students enrolled at Chicago State University.

Policy Guidelines

Employees

  1. The university absolutely prohibits the unlawful manufacture, distribution, dispensation, possession, or use of a controlled substance or alcohol on university premises or while conducting university business off university Violation of this policy may result in immediate termination of employment or other appropriate disciplinary actions.

Controlled substances are those usually referred to as illegal drugs listed under the federal Controlled Substances Act.

  1. In compliance with the drug-FreeWorkplace Act of 1988 and the federal Drug-Free Schools and Communities Act Amendments of 1989, and as a condition of employment with Chicago State University, all staff must
  • Abide by the prohibition in point II.A. (See above).
  • Notify the Director of Human Resources of any conviction under a criminal drug statute for violations occurring on or off university premises while conducting university business, within 5 days after conviction.

When the Department 0f Human Resources receive notice of such a conviction, it will coordinate efforts to comply with the reporting requirements of the Drug-Free Workplace Act of 1988.

  1. An employee who is (1) found to be under the influence of alcohol or a controlled substance while on university property, or in the course of a university activity, or (2) convicted of a criminal alcohol or drug statute violation occurring on university property, is subject to disciplinary action, up to and including
  1. If it can be reasonably established that an employee's use of alcohol or a controlled substance away from the university causes poor attendance or performance problems, then the person will be counseled to seek You may contact the University Counseling Center Substance Abuse Referral Office at 773-995-2383(Students) or (Employees) Employee Assistance Program at 866-659-3848.
  1. The Human Resources Department will maintain and periodically publish a list of available university and community resources for alcohol or drug The publication must include this information:

          Resourcesthatofferassistance(drug counseling, employee assistance programs)

           Rehabilitation programs

           Dangers of alcohol or drug abuse in the workplace

Students

Students who violate this policy will be referred to the Office of Student Affairs for disciplinary action in accordance with the Policy on Student Conduct. Possible disciplinary sanctions for failure to comply with the terms of this policy may include one or more of the following:

(1) Expulsion; (2) suspension; (3) mandatory participation in and satisfactory completion of a drug/alcohol abuse program or rehabilitation program; (4) referral for prosecution; (5) probation and restriction of privileges.

Criminal Penalties

All employees and students are reminded that conviction under state and federal laws that prohibit alcohol and drug-related conduct can result in fines, confiscation of automobile and other property, and imprisonment. A conviction can also result in the loss of a license to drive or to practice in certain professions, and barred opportunities from employment.

Arrest and conviction of a drug law violation can result in the following:

  • Fines (up to $500,000 under state law and $250,000 under federal law)
  • Confiscation of automobiles and other property
  • Imprisonment (up to 60 years under state law and life under federal law)

A person who exhibits the following alcohol-related behavior is at risk of arrest:

  • A person under 21 who possesses alcohol
  • A person who provides alcohol to a person under 21 A person who is intoxicated in public
  • A person who sells alcoholic beverages without a license IV Health Risks Associated with Alcohol
  • All persons should be aware of the following health risks caused by alcohol:
  • Consumption of more than two average servings of alcohol in several hours can impair coordination and reasoning, and make driving an unsafe activity. 

Health Risks Associated with Alcohol

All persons should be aware of the following health risks caused by alcohol:

  • Consumption of more than two average servings of alcohol in several hours can impair coordination and reasoning, and make driving an unsafe activity.

  • Consumption of alcohol by a pregnant woman can damage the unborn child. A pregnant woman should consult her physician about this risk.

  • Regular and heavy alcohol consumption can cause serious health problems such as damage to the liver and to the nervous and circulatory systems.

  • Drinking large amounts of alcohol in a short time may quickly produce unconsciousness, coma, and even death. 

Health Risks Associated with Drugs

The health risks associated with controlled substances are numerous and varied depending on the drug. Nonetheless, the use of drugs not prescribed by a physician is harmful to the health. For example, drug use can cause the following conditions: 

  • Impaired short-term memory or comprehension
  • Anxiety, delusions, and hallucinations
  • Loss of appetite resulting in damage to one's long-term health
  • A drug-dependent newborn, if the mother uses drugs during pregnancy

Pregnant women who use alcohol or drugs, or who smoke should consult their physician.

  • AIDS, as a result of drug users who share needles
  • Death from overdose

Ethics Compliance

Program for Compliance with the State Officials and Employees Ethics Act PA 93-0617

The new State Officials and Employees Ethics Act (“SOEEA”) requires the Illinois public university governing boards in coordination with the Illinois Board of Higher Education to demonstrate they have adopted and implemented for all employees under their respective jurisdiction and control specific personnel policies relating to (a) work time requirements, (b) documentation of time worked, (c) documentation for reimbursement of authorized travel expenses while on official State business, compensation, and the earning or accrual of State benefits for all State employees who may be eligible to receive those benefits. 5 ILCS 430/5-5.

“….The president or designee is fully authorized to adopt necessary standards and implementing procedures in order to effectuate the Institution’s Policies and Board Regulations and maintain them in accordance with applicable laws or regulations. The president or designee shall, at the request of the Board or the Board Chair, issue interpretive memoranda in response to questions of interpretation.” Where necessary or appropriate the president may authorize updates to this program of compliance.

The following personnel policies are in effect to assure Chicago State University (CSU) is in appropriate compliance with the State Officials and Employees Ethics Act, all other applicable state laws, and the standards previously established by the Board of Trustees of CSU. Any policies stated herein that were not previously in effect are automatically effective by operation of law through authority of the Board of Trustees of Chicago State University and provisions of its Bylaws no later than March 4, 2004 to the extent authorized or required by applicable laws.

Designation of Contact Persons

  • Robin M. Hawkins, Esq. is the individual assigned by the President to serve as Ethics Officer for CSU.
  • Lindsay Hamilton, Director of Human Resources (or designee), is the individual assigned by the President to provide information and respond to inquiries about CSU personnel policies.

Personnel Policies Required by the State Officials and Employees Ethics Act

Applicable CSU Policies

CSU’s Institutional Policy Manual, Article XII, Section 1, establishes policies pertaining to political activity in relation to publicly supported work time or resources. These Regulations read as follows:

" Chicago State University is an institution of Higher Education created, funded and governed by the Illinois Legislature. As such, soliciting support or money for any political party or candidate on University property, owned or leased, is prohibited.”

Accordingly, no political activity prohibited by the State Officials and Employees Ethics Act shall be conducted on university property or resources by any university employee or member of the Board of Trustees of Chicago State University.

Nothing in this policy statement prohibits activities that are otherwise appropriate for a university employee or Trustee to engage in as a part of his or her official university duties, or activities that are undertaken by a university employee or Trustee on a voluntary basis as permitted by law.

Work Time Accounting

CSU policies and procedures provide for periodic reporting and accounting of the accrual and utilization of State benefits. New requirements of the State Officials and Employees Ethics Act relate to work time requirements and documentation of time worked. For each category of CSU employee, the following procedures shall apply:

Work Time Requirements and Reporting

Chicago State University maintains operations on a 7-day, 24-hour, per week basis. Individual work responsibilities naturally vary according to assignments and roles. Throughout this entire time frame, faculty and staff work schedules and task completion responsibilities are assigned to pursue and maintain the instruction, scholarship, public service and outreach commitments; organizational/administrative functions; and operations required to fulfill the university’s mission and functions. By way of example, individuals’ responsibilities may include: classroom, laboratory or field instruction, and associated preparation; evaluation and grading; one-on-one work; continuing professional education and development to maintain current competencies in relevant fields of knowledge; participation in university organizational and disciplinary professional events; and representing the university throughout a variety of time periods that include evenings and weekends.

Unless otherwise required by unusual circumstances, normal university department office hours are 8:30 a.m. through 5:00 p.m. Monday through Friday with lunch periods designated by individual departments. Work hours pertaining to individual instructional/scholarship, services, and administrative responsibilities extend throughout the 7-day, 24-hour, workweek as necessary to maintain operations and fulfill the university’s mission.

Work schedules applicable to all full-time administrators, shall assume a minimum schedule of 40 hours of work per week. All exempt, non-negotiated civil service staff shall work 37.5 hours per week. All non-exempt, non-negotiated staff shall work a minimum schedule of 35 hours of work per work. All negotiated faculty, administrators, and staff shall work the hours as set forth in their contractual labor agreements. Expectations for part-time schedules are assigned proportionately. For purposes of compensation rates, the federal Fair Labor Standards Act (FLSA) exempts faculty, professional, and administrative staff from maintaining specific and limited work hours (normally extending well beyond the minimum hourly standard) as necessary to fulfill their assigned responsibilities.

For purposes of this policy statement, CSU employees are subdivided into three categories (Hourly/FLSA Non-Exempt, Salaried/FLSA-Exempt, and Faculty/Instructional):

1.Hourly/FLSA Non-Exempt Employees

The Hourly employee category includes all hourly-paid civil service, extra help, student, and non-status employees of Chicago State University. For these positions, the Documentation of Time Worked requirements of the State Officials and Employees Ethics Act shall be fulfilled through compliance with Board of Trustees Regulations. Accordingly, no Hourly employee may engage or be required to engage in prohibited political activity (as defined by applicable CSU policies and the State Officials and Employees Ethics Act) that would interfere with the normal execution of their duties and responsibilities, nor involve the use of university property or resources, for any time period during the employee’s appointment with Chicago State University. Employees must utilize available vacation/personal leave benefits or declare time off without compensations, for any activity undertaken during their normal work schedule that would fall under the definition of Board of Trustees Regulations.

2. Salaried/FLSA-Exempt Employees

The Salaried/FLSA-Exempt category of employment includes all salaried supportive professional Staff, administrative exempt civil service, and other employees appointed for time frame that do not correspond with the academic calendar (i.e., greater than 9-month appointments eligible for vacation accrual). For these positions, the Documentation of Time Worked requirements of the State Officials and Employees Ethics Act shall be fulfilled through compliance with Board of Trustees Regulations. Accordingly, no Salaried/FLSA-Exempt employee may engage or be required to engage in prohibited political activity (as defined by applicable CSU policies and the State Officials and Employees Ethics Act) that would interfere with the normal execution of their duties and responsibilities, nor involve the use of university property or resources, for any time period during the employee’s appointment with Chicago State University. Non-instructional salaried employees must utilize available vacation/personal leave benefits, or declare time off without compensation, for any activity undertaken during their normal work schedule that would fall under the definition of Board of Trustees Regulations.

3. Faculty/Instructional Employees

The Faculty/Instructional employee category includes all tenured and tenure-track faculty, part-time lecturers, instructors, visiting, affiliate, graduate assistant and any other employees appointed for time frames that correspond with the academic calendar ( i.e., 9-month appointments not eligible for vacation accrual). For these positions, the Documentation of Time Worked requirements of the State Officials and Employees Ethics Act shall be fulfilled through compliance with Board of Trustees Regulation. Accordingly, no Faculty/Instructional employees may engage or be required to engage in prohibited political activity (as defined by applicable CSU policies and the State Officials and Employees Ethics Act) that would interfere with the normal execution of their duties and responsibilities, nor involve the use of university property or resources, for any time period during the faculty member’s appointment with Chicago State University. Faculty/instructional employees must utilize available leave benefits (if any), or declare personal time off without compensation, for any activity undertaken during their normal work schedule that would fall under the definition of Board of Trustees Regulation.

It shall be the responsibility of all CSU employees to comply with the provisions of the State Officials and Employees Ethics Act and the work time accountability requirements specified in this policy statement and other applicable regulations/procedures. CSU will maintain compliance with these procedures and employees will be held fully accountable for any proven violations of the State Officials and Employees Ethics Act.

Documentation for Reimbursement for Travel on Official State Business, Earning of Compensation and Accrual of State Benefits

Documentation requirements for reimbursement of official university travel expenses must comply with rules of the Higher Education Travel Control Board and relevant CSU Board of Trustees Regulations.

Documentation requirements for earning of compensation for services, and accrual of State benefits such as vacation, sick leave, bereavement leave, leaves of absence, holidays, unpaid personal leave, disability and retirement shall be maintained in accordance with applicable university policies, procedures and interpretations which are made a part of this compliance program. Eligible leave time benefit utilization shall be documented on applicable time cards and the weekly attendance record sheets for all CSU employees.