Fraud and Theft Prevention Policy

PURPOSE:
To prevent and detect fraud and theft, assign responsibility for implementing appropriate controls to prevent
and detect fraud and theft, establish the appropriate reporting mechanisms to be used for notification of known
or suspected fraud and theft, and establish the consequences for fraud and theft by employees.
APPLIES TO:
All O2O Holdings (PTY) LTD employees, customers, contractors, consultants, or other parties related to the
O2O Holdings.

POLICY STATEMENT:
Scope of Policy
O2O Holdings employees must comply with applicable state and national law.

As a publicly supported company, O2O Holdings has a fiduciary responsibility to conserve, preserve, and
efficiently use all company resources.

This policy applies to any known or suspected fraud or theft involving employees, customers, , contractors,
consultants, or other parties related to the O2O holdings (PTY) LTD.

Prevention and Detection of Fraud and Theft

O2O holdings employees shall not perpetrate, engage in, or otherwise facilitate the act of committing fraud and
theft.

The Managing director and Operational Manger are responsible for establishing the controls to prevent and
detect fraud and theft. The management are responsible for knowing the types of improprieties that might
occur within their areas of responsibility and for identifying and assessing any irregularities. O2O Holdings
employees are responsible for the prevention and detection of fraud and theft that might occur within the scope
of their work assignments and for reporting any known or suspected fraud and theft.

Reporting Known or Suspected Fraud and Theft

Employees are responsible for immediately reporting known or suspected incidents of fraud, including theft
and misappropriation of University Assets, to either the Internal Audit Department or the appropriate campus
Public Safety office.

Any employee who has knowledge of fraud or theft of University Assets by any person or organization,
including another employee, and does not report it to University officials may be subject to disciplinary action,
up to and including termination of employment.
If the initial notification is to the Internal Audit Department, Internal Audit shall notify the appropriate campus
Public Safety office and vice versa.

Investigation of Reports of Known or Suspected Fraud and Theft

The campus Public Safety office shall investigate allegations of fraud and theft in accordance with University
established policies and procedures.
The Internal Audit Department shall be responsible for ascertaining the extent of loss, and for reviewing and
evaluating control and/or process failures related to the loss. Internal Audit will also notify the University
Chief Business and Financial Planning Officer, Office of the General Counsel, the Provost/Executive Vice
Chancellor, Lawrence Campus, and/or the Executive Vice Chancellor, Medical Center.
Any employee who suspects fraudulent activity should not attempt to personally conduct an investigation
related to the activity. If the employee elects to notify department management first, then department
management must immediately notify the Internal Audit Department or the appropriate campus Public Safety
office before taking any other action. Concerns about work performance and workplace behavior that are
unrelated to fraudulent activity should be resolved by department management and Human Resources
(Lawrence) or Human Resources (Medical Center): they should not be reported under the fraud and theft
policy. If there are any questions about what constitutes fraud and theft, the Internal Audit Department should
be contacted.
Reports and investigations of allegations of fraud and theft ordinarily will be kept confidential to the
reasonable extent possible under law and consistent with the need to conduct an adequate investigation and
take corrective action.
CONSEQUENCES:
If appropriate University officials conclude that an employee has engaged in fraud or theft, appropriate
disciplinary action will be pursued, up to and including termination of employment, in accordance with
applicable personnel policies for faculty and staff. In addition, employees engaging in fraud or theft will be
required to pay restitution, including the cost of the investigation.
Employees of the University of Kansas who engage in fraudulent activity or theft are not acting within the
scope of their employment and should not expect protection for their acts under either the Kansas Tort Claims
Act or any applicable University insurance policy.
It is the policy of the University of Kansas to pursue legal action based on the merits of the case in consultation
with the Office of the General Counsel.

Ordinarily, the submission of a resignation by an employee accused or suspected of fraud or theft will not
preclude later disciplinary action, including restitution and legal action. If restitution is required, payment
arrangements will be established with the office of the Provost/Executive Vice Chancellor, Lawrence Campus,
or the Executive Vice Chancellor, Medical Center.
CONTACT:
Department of Internal Audit
Strong Hall
1450 Jayhawk Blvd., Suite 351
Lawrence, KS 66045
Fraud Hotline: 785-864-1300
reportfraud@ku.edu

Office of the General Counsel

Strong Hall
1450 Jayhawk Blvd., Suite 245
Lawrence, KS 66045
785-864-3276
The University of Kansas, Lawrence campus
Office of the Provost and Executive Vice Chancellor
Strong Hall
1450 Jayhawk Blvd., Suite 250
Lawrence, KS 66045
785-864-4904
provost@ku.edu
University of Kansas Medical Center
Office of the Executive Vice Chancellor
2032 Murphy Administration Building
Mail Stop 2015
3901 Rainbow Boulevard
Kansas City, KS 66160
913-588-1440
Note: The Office of the General Counsel is key contact for policy interpretation, enforcement, and other issues
not specifically addressed in this policy.
APPROVED BY:
Chancellor
APPROVED ON:
Friday, December 11, 2009
EFFECTIVE ON:
Friday, December 11, 2009
REVIEW CYCLE:
Annual (As Needed)
BACKGROUND:
Organization responsible for appropriate execution of this policy:

 Department of Internal Audit

 Office of the General Counsel
 Office of the Provost/Executive Vice Chancellor, Lawrence Campus
 Office of the Executive Vice Chancellor, Medical Center
RELATED STATUTES, REGULATIONS, AND/OR POLICIES:
University of Kansas Whistleblower Policy
KU Medical Center (KUMC) Policies, Procedures, Operational Protocols
DEFINITIONS:
University Employee: includes faculty, unclassified academic staff, unclassified professional staff, University
Support Staff, classified staff, and student employees, regardless of nature of appointment.
University Assets: include, but are not limited to money, negotiable securities, supplies, equipment, facilities,
licenses and rights, and all other property owned by or entrusted to the University for the purpose of carrying
out University functions. This includes all assets regardless of where they are located or by whom they are
held. This includes services provided by the University.
Misappropriation or Misuse (intentional): the unauthorized use or control over University Assets by an
employee with the intent to deprive the University of temporary use of the Assets.
Theft: a taking of University Assets that results in a loss to the University. Examples of theft include:
 Obtaining by fraud, control over University Assets with the intent to permanently deprive the
University of ownership;
 Embezzlement;
 Using University assets for personal purposes except for permitted incidental personal use;
 Authorizing or receiving payments for goods not received or services not performed;
 Authorizing or receiving payment for hours not worked;
Fraud: the deliberate misrepresentation of fact for the purpose of depriving the University permanently of
property or legal right to property. Examples include, but are not limited to:
 Corruption: conflicts of interest, bribery, illegal gratuities, and economic extortion
 Cash asset misappropriation: larceny; skimming; check tampering; and fraudulent
disbursements, including billing, payroll, and expense reimbursement schemes.
 Non-cash asset misappropriation: larceny; false asset requisitions; destruction, removal or
inappropriate use of records and equipment; inappropriate disclosure of confidential
information; and document forgery or alteration
 Fraudulent statements: financial reporting, employment credentials, and external reporting
 Fraudulent actions by customers, vendors or other parties include bribes or inducements, and
fraudulent (rather than erroneous) invoices from a supplier or information from a customer.
KEYWORDS:
Cash, conflicts of interest, embezzlement, fraud, illegal and/or prohibited use, improprieties, intentional
misuse, misappropriation, misrepresentation, money, negotiable securities, theft, unauthorized use, University
assets