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Middlebury College
Accounting and Financial
Accounting and Auditing Matters The unethical systematic recording and analysis of the business and financial transactions associated with generally accepted accounting practices. (Examples include: misstatement of revenues, misstatement of expenses, misstatement of assets, misapplications of GAAP principles, wrongful transactions)
Conflict of Interest A situation in which a person or a family member has a financial interest or non financial interest that may compromise, or provide the incentive to compromise, the behavior in the conduct of the person's duties at the institution, the person's influence on decisions that the institution may make, or the person's influence over his or her associates outside the institution. A conflict of interest may be real, potential or apparent.
Donor Stewardship Mishandling of donor funds directed to the institution, including funds that may not have been used in accordance with the donor's intentions and wishes.
Falsification of Contracts, Reports or Records Falsification of records consists of altering, falsifying, or forging all or any part of a document, contract or record for the purpose of gaining an advantage, or misrepresenting the value of the document, contract or record. Failure to complete and post or file data and reports required by law to governmental agencies. (Examples include: Financial Aid documents, Vendor Contracts)
Fraud The intentional misrepresentation or concealment of information in order to deceive, mislead, or acquire something of value. A fraud is an intentional deception perpetrated to secure an unfair gain.
Improper Disclosure of Financial Records Careless, unlawful or fraudulent conduct in recording, preparing, reporting, disclosing of either the value or the content of a contract, report, statement, document, record, or electronic file.
Improper Giving or Receiving of Gifts The giving, receiving or solicitation of items which could be reasonably interpreted as an effort to influence a business relationship or decision; items given, received or solicited for the benefit of an individual or an individualís family or friends; items given, received or solicited during or in connection with contract negotiations; the acceptance of cash, checks, money order, vouchers, gift certificates, loans, products or services.
Improper Supplier or Contractor Activity Supplier or contractor activity in violation of institutionís policies and procedures; improper supplier or contractor selection based on personal gain, improper negotiation or diversion of contract awards.
Research Grant Misconduct or Misappropriation of Costs Unallowable or questionable expenditures or cost transfers to government grants, contracts or other agreements. Any expenditures or cost transfers that may be in violation of OMB Circular A-21.
Scholarship / Financial Aid Misconduct Falsifying entrance or placement exams; utilizing an assumed name; improper inducement of benefits or financial aid. Unusual treatment for one player and not for others in loans, transportation or housing benefits; arranging for fraudulent academic credit or falsification of transcripts.
Theft / Embezzlement The act of stealing; specifically: the felonious taking and removing of personal property with intent to deprive the rightful owner of it. To appropriate (as property entrusted to one's care) fraudulently to one's own use (Examples include: intentional bookkeeping errors)
Waste, Abuse or Misuse of Institution Resources Improper or unauthorized use of this institution's resources and technologies for personal gain.
Other Financial Matters Other matters of concern not specifically outlined above.