Public Research Fund Misappropriation Prevention Plan at National University Corporation Tokushima University

(Decision by President)
(October 31,2007)

Revised on April 1,2010

Revised on July 1,2011

Revised on April 1,2013

Revised on November 1,2014


 In order to ensure proper uses of public research funds at National University Corporation Tokushima University (hereinafter referred to as“University”), the following misconduct prevention plan shall be established and thoroughly implemented, as stipulated in Article 9 of the “Rules on Handling of Public Research Funds at National University Corporation Tokushima University.”


1 Preparation and improvement of operation/management system

(1)Clear identification of responsibility structure/system

 The responsibility structure/system for operation and management of public research funds at the University shall be clearly identified and publicized in the University Web site, etc., designating the President as the Chief Executive Officer, an Executive Director (in charge of research) as Chief Operating Officer, and, as a general rule, the head of each department as a compliance promotion manager, who should then be assisted by an assistant compliance promotion manager in a department where the compliance promotion manager is appointed.


(2)Establishment of competitive fund consultation office

 In order to ensure that the procedures for subscription/grant application for competitive funds and the relevant rules are thoroughly communicated/understood and uniformly implemented, a consultation office shall be established and research activities are promoted efficiently. The availability of the consultation office should be thorough communicated to the relevant parties.


 (3)Enhancement of internal audit system

 The Audit Office conducts monitoring and internal audits in coordination with the Misconduct Prevention Plan Promotion Office, from the comprehensive University-wide perspective, and inspects/verifies any systemic defects.

 The Audit Office shall also exchange information with the Auditor and accounting auditors concerning causes of misconduct and priority audit items, etc., and implements internal audits according to the audit manuals efficiently, effectively, and multi-dimensionally.


2 Thorough implementation of compliance measures

 The compliance promotion manager conduct education/training for raising awareness of the entire University staff to prevent misconduct relating to public research funds and to promote proper management by following the instructions of the Chief Operating Officer.

 The Misconduct Prevention Plan Promotion Office shall ensure that the Tokushima University Codes of Conduct and other relevant rules are thoroughly communicated to, and understood by, researchers, etc. through its Web site, etc. Faculty and staff members, as well as students, who took the education/training courses, and researchers for whose projects competitive funds have been adopted, must submit written pledges to the effect that they understand and comply with the relevant rules.


3 Proper operation and management activities for public research funds

(1)Clear identification of job functions and relevant rules

 For proper clerical handling of public research funds, the researchers and the clerical staff members should clearly distinguish their respective authorities and responsibilities, and share common understanding about them. It is also necessary confirm that no significant deviation takes place between the relevant rules and the actual operational conditions so that the public research funds can be operated and managed properly.


(2)Written pledges to be collected from trading partners

 All parties conducting transactions with the University must be requested to submit written pledges stating that, among other things, they will comply with the relevant University rules, etc., never commit any misconduct or inappropriate act, and cooperate with audits and investigations conducted by the University.


(3)Thorough implementation of receiving inspections and commodity management

 For all items delivered to the University, the personnel in charge of receiving inspections (accounting staff members) shall conduct thorough receiving inspections by collating the individual items with information in order forms and invoices, to prevent any delivery service providers from taking them back or using the same documents repetitiously. However, concerning items for which receiving inspections by the personnel in charge of the task are difficult (radioisotopes and laboratory animals, etc.), the personnel of the respective delivery sites should be designated as receiving inspection managers and carry out the inspections properly. As for special services, etc., the personnel in charge of receiving inspections (accounting staff members) or the personnel other than those who placed the orders and were capable of checking the contents should be designated as the receiving inspection manager and carry out the inspections properly. The accepted items shall be properly managed according to the relevant University rules. Specifically, PCs and other items that may be easily converted into cash shall be managed properly, regardless of the monetary amounts.

 Items that have not been inspected by the personnel in charge of receiving inspections or the receiving inspection manager shall not be deemed to have been delivered to the University; and delivery service providers that do not undergo proper receiving inspections shall be sanctioned strictly, including transaction suspension, etc.


(4)Confirmation of facts about travel expenses

 In submitting a report on a business trip, the main purpose of which is to attend meetings on researches, the person who went on a business trip shall attach copies of materials with which the facts, including dates and time of the discussions with the other parties, can be confirmed. In the case of attendance in academic association meetings, copies of materials with which the facts can be confirmed must be attached to prove the fact indubitably.


(5)Confirmation of actual payment of remuneration

 Prior to starting operations, the operation performing parties (students, etc.) shall receive instructions/explanations about work conditions/requirements and misappropriation, etc. from the relevant departmental clerical staff, and have the contents of the operations checked by the operation requesting parties (researchers) at the end of each day, submit a monthly implementation completion report to the personnel in charge of confirming departmental administration, who shall then check the contents of the operations, etc. thoroughly, based on the submitted implementation completion report.


4 Clear indication of misappropriation response procedures, etc.

(1)Establishment of misappropriation whistle-blowing contact point

 A contact point to receive allegations and consultation concerning misconduct shall be established, which shall be an existing whistle-blowing contact point in consideration of convenience of complainants, etc. expeditious responses, and centralized management of information, etc. The availability of the misappropriation whistle-blowing contact point shall be thoroughly communicated throughout the organization.


(2)Clear indication of misappropriation response procedures

Actions against misappropriation shall be handled properly in accordance with the “Rules on Handling of Public Research Funds at National University Corporation Tokushima University” (hereinafter referred to as “Misappropriation Handling Rules”)

 If any misappropriation is deemed to have occurred, the investigation results shall be disclosed in accordance with the Misappropriation Handling Rules, and proper measures, including necessary sanctions, etc., shall be taken in accordance with the relevant rules.


5 Inspection/evaluation of misconduct prevention plan

 The Misappropriation Prevention Plan Promotion Office shall always endeavor to follow up on causes of misconduct relating to public research funds, inspect/evaluate the misappropriation prevention plans, and revise them, as appropriate.