Due to overlap of responsibilities, all Internal Audit activities will be coordinated with Compliance, Enterprise Risk Management, and Privacy. In addition, Internal Audit will coordinate efforts, as needed, with Finance, Legal Counsel, IS&T Security, Public Safety, Human Resources, and any other compliance function, such as Research.  

From time to time, suspected improprieties are identified by employees, management, Public Safety, and Human Resources. Responsibility for investigation of such improprieties will depend on the circumstances and the financial amounts involved.

• For loss or theft of physical assets, Public Safety will be contacted for investigation.
• For loss or theft of cash (currency, checks, or other cash equivalents), Public Safety will also notify Internal Audit to consider whether a review of internal controls is necessary and/or to quantify the loss if it is not an isolated incident.
• For any other suspected financial improprieties, including timekeeping, Internal Audit should be contacted.
• For any suspected security breach, the IT Security Officer will be responsible for the investigation and will request assistance from the Privacy Officer as applicable.
• For any improprieties regarding billing and reimbursement, the Office of Compliance will be responsible for the investigation.
• If any suspected issues arise with respect to grant administration, such as effort reporting or subrecipient compliance, Internal Audit will lead the investigation.
• For any improprieties that may affect Jefferson’s compliance with laws and regulations, are potential conflicts of interest, or are ethical issues, the matter should be reported to the Office of Compliance.
• If there is a question of responsibility for the investigation, the Chief Legal Officer will be consulted to assign responsibility for the investigation.
• To the extent that any Internal Audit investigation provides evidence that an employee has misappropriated funds or other assets, both Human Resources and Legal will be contacted for further action. Any investigation that provides evidence that an external party has misappropriated funds or other assets from Jefferson, this will also be reported to Legal to arrange for recovery and/or other actions.