1. Statement of Ethical Conduct Our Commitment To Integrity And Ethical Conduct 1

2. Statement of Ethical Conduct Driven by the University’s mission of teaching, research, and patient care – Sets expectation of highest standards of ethical conduct – Commits to upholding the reputation of the University – Encourages compliance with applicable laws, regulations, and University policies – Does not condone retaliation for any good faith report of improper activity 2

3. Statement of Ethical Conduct Be honest, ethical, truthful Obey the law Follow University policies and procedures 3

4. What Is Honesty? Honesty is – Fairness – Forthrightness – Straightforward conduct – A refusal to lie, steal or deceive Honesty is taking responsibility for one’s own actions 4

5. What Is Fraud? Fraud is an intentional act calculated to deceive by – Affirmative act – Concealment – Omission …that results in damage to an individual or organization and violates a legal or equitable duty owed 5

6. Impact Of Dishonesty And Fraud Fraud and dishonesty cause – The destruction of institutional and personal reputation, loss of respect, and loss of public esteem – Criminal and civil penalties, fines, suspension, terminations and the destruction of careers – U.S. organizations to lose an estimated five (5%) percent of their annual revenues 6

7. Identifying And Reporting Fraud The five most reported schemes of fraud are: – BILLING SCHEMES – employee causes the business to issue payment for fictitious goods or services or payment for services that were personal to the employee – PAYROLL SCHEMES – employee caused the business to issue payment for compensation for false claims of work – EXPENSE REIMUBURSEMENT SCHEMES – employee makes a claim for reimbursement for a fictitious, or inflated, or personal expense – CHECK TAMPERING – employee steals funds by forging or altering a business check – CASH REGISTER DISBURSEMENT SCHEMES – employee makes false entries on a cash register to conceal removal of currency 7

8. Who Reports Fraud, And How? Fraud is discovered 46% of the time due to a tip provided by an individual – Of the fraud tips provided, 59.6% come from company employees – 35% from customers or vendors – 5% by internal or external audit and by chance Organizations with anonymous reporting systems cut their fraud losses by 50% 8

9. What Is Ethical Conduct? Conduct conforming to the law and regulations, professional standards, and the policies of the University – A Statement of Ethical Conduct expresses a set of values and defines the purpose of an individual or organization – A Statement of Ethical Conduct says: “This is who we are and this is what we stand for” 9

10. What Is Compliance? A willingness to follow a prescribed course of action – Acting according to certain accepted standards – Observance of official requirements 10

11. Columbia’s Compliance Hotline 11

12. 12 Compliance Hotline A 24/7 confidential channel for employees to report or seek guidance on incidents of financial impropriety Enhances the set of existing services and channels that support integrity and compliance – EVP for Research – Billing Compliance – Human Resources – Internal Audit – Ombuds Office

13. Why Is This Important? We want to give employees every possible means to report fraud, abuse, and conflicts of interest -- and the understanding of why it is important to do so – Less than one-half of all organizations encourage discussion of moral dilemmas and criticism of unethical conduct 13

14. 14 Columbia’s Compliance Hotline Provided and administered by a third party -- Global Compliance 24-hour telephone and web-based channels – (866) 627-3768 – https://www.submitreport.com/columbiauniversity.jsp Confidential intake and report handling – Option to report anonymously

15. Focus Of The Compliance Hotline University-wide scope – Fraud and financial improprieties – Research misconduct – Conflicts of interest – Breaches of confidentiality or destruction of information – Discrimination or harassment 15

16. Options -- How, Where to Report If possible, reach out to your supervisor first – As an alternative, identify the proper channel for seeking guidance, reporting, or resolution – Compliance Hotline 16