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Establishment of a system for managing and auditing public research funds and a plan to prevent fraud

Aoyama Gakuin University Based on the "Guidelines for Management and Audit of Public Research Funds at Research Institutes (Implementation Standards)" (revised on February 1, 2021) by the Ministry of Education, Culture, Sports, Science and Technology, MEXT has established a system for proper operation and management of public research funds and a system of responsibility, and has established "Aoyama Gakuin University Rules on the Implementation System of Operation, etc. of Public Research Funds," "Aoyama Gakuin University Detailed Rules on Response to Misconduct in the Use of Public Research Funds," and " The "Aoyama Gakuin University Detailed Regulations on the Response to Misconduct in the Use of Public Research Funds" and the " Internal Regulations on the Use of Public Research Funds" have been established to prevent misconduct on a daily basis.
In April 2013, the Receiving and Inspection Center was established to improve the scope of acceptance inspection, the person who conducts acceptance inspection, and the method of acceptance inspection, thereby strengthening the operation and management system of public research expenses.
Aoyama Gakuin University will establish a fraud prevention plan based on the fraud prevention system, ensure transparency and reliability in the operation and management of expenses, including public research funds, and strive to further enhance and develop its activities as an educational and research community of "salt of the earth and light of the world" that serves God and people and contributes to society. In line with this basic policy, we will continue to work on fraud prevention activities.

Aoyama Gakuin University the greatest of all

Clarifying the responsibility system

■Chief Administrative Officer: President
It oversees the entire university and is ultimately responsible for the operation and management of research funds, etc.

■Chief Administrator: Vice President for General Affairs
The Chief Administrator will assist the Chief Administrator and will have actual responsibility and authority for overseeing the operation and management of research funds, etc. for the entire University.

■ Compliance Promotion Officers: General Manager, graduate school deans, some center directors, and Director, The University Administration
As Compliance Promotion Officer, you will have actual responsibility and authority for the operation and management of research funds, etc. within each faculty, graduate school, administrative office, etc. within the university.
In addition, the Compliance Promotion Officer will clarify the scope of responsibility for each faculty, graduate school, center, etc., or administrative office, etc. that he or she manages, supervises, or guides, by appointing a Deputy Compliance Promotion Officer in each faculty, graduate school, center, etc., or administrative office, etc. that he or she manages, supervises, or guides, and by establishing a system for effective management and supervision.

■ Deputy Compliance Promotion Officer
Assists the Compliance Promotion Officer.
The deputy compliance promotion officers in University Administration will be the head of Administrative Affairs Department, Accounting Division Administrative Affairs Department, Manager the Facilities Section Administrative Affairs Department, and Sagamihara Campus Administration Department, and the others may be appointed by Director, The University Administration, who is the compliance promotion officer.

■ Departments promoting the fraud prevention plan: Research Support Department and Sagamihara Campus Administration Department Research Promotion Division
We are formulating and implementing specific measures across the university and are monitoring their implementation.

Code of Conduct for the Management and Administration of Public Research Funds

In accordance with our educational policy and the university philosophy, which are based on Christian faith, our university has established a Code of Conduct that sets out standards of behavior (attitude) when conducting research, etc., in order to ensure the reliability and fairness of academic research, which is of a public nature, and to secure society's trust in the university's academic research activities.

Aoyama Gakuin University University Code of Conduct for the Management and Administration of Public Research Funds

Creating an environment that serves as the basis for proper operation and management

The university has established the "Aoyama Gakuin University Internal Regulations for the Use of Public Research Funds" and has made them known to all researchers and administrative staff. The General Manager constantly reviews the internal regulations to ensure that an appropriate checking system is maintained, and consults on amending the internal regulations as necessary. Each faculty has also established a system for informing faculty members about compliance with the internal regulations at their respective faculty meetings.

Establishment of a system to ensure the transmission of information

Our university has compiled a "Handbook for Handling Grant-in-Aid Expenditures, etc." and makes it available to the public on our information website for researchers (http://rs.aoyama.ac.jp/). We also hold an information session for grant recipients around June each year, where the secretariat touches on the importance of institutional management and repeatedly explains the need to comply with the researcher usage rules, other relevant laws and regulations, and various university-related rules, in order to ensure that this information is fully understood.
Consultations regarding rules concerning the use of public research funds are accepted and handled by Research Support Department, the Research Promotion Division Sagamihara Campus Administration Department, Accounting Division Administrative Affairs Department, and the General Sagamihara Campus Administration Department.
In order to take strict measures against fraudulent activities and to check and detect violations of laws and regulations at an early stage, we have set up a desk (hereinafter referred to as the "Desktop Desk") within the Legal Legal Affairs Division Division, General Affairs Department to receive reports, information or complaints (hereinafter referred to as the "Reports, Legal Affairs Division") regarding fraudulent activities. In addition, we have set up a desk outside the Corporation to receive reports, etc.
For specific details, please see the "Contact point for reporting misconduct in the use of public research funds" below.

It is stipulated that when the hotline receives a report, it must promptly report the contents of the report to the Chief Management Officer through the General Management Officer.
In order to protect those who report or make allegations to the Hotline (hereinafter referred to as "whistleblowers") and those who provide information (hereinafter referred to as "information providers"), we have established confidentiality regulations to guarantee the confidentiality of the names of whistleblowers and information providers (hereinafter referred to as "whistleblowers, etc.").
In addition, the company stipulates that those who cooperate with the investigation (hereinafter referred to as "investigation collaborators") must not be treated unfavorably because they have cooperated with the investigation, and that disciplinary action or other appropriate measures will be taken in accordance with the company's rules of employment against anyone who treats them unfavorably because they cooperated with the investigation.

Contact point for reporting misconduct in the use of public research funds

Establishment of rules regarding investigations and disciplinary measures and transparency of their implementation

The procedures and operations of investigations into misconduct are stipulated in the "Aoyama Gakuin University Detailed Rules for Responding to Misconduct in the Use of Public Research Funds," which divide them into preliminary investigations, main investigations, and reinvestigations.
The bylaws also state that, with regard to investigations, anyone involved in the University's response to misconduct must respect the honor, privacy and other human rights of those involved and must not disclose any secrets that they may have learned. They also state that whistleblowers and other investigators must not be treated unfavorably for having cooperated with the investigation.
Furthermore, the bylaws stipulate that the University will take the following measures in response to an investigation: "If it is determined that misconduct has occurred, the Chief Administrator shall promptly take corrective measures and measures to prevent recurrence." "If the misconduct is deemed to be highly malicious, such as involving private misappropriation, the Chief Administrator shall take legal action if he or she deems it necessary." "If it is not determined that misconduct has occurred, the Chief Administrator shall take measures as necessary to prevent any disadvantage to the whistleblower, the subjects of the investigation, and other related parties."

Developing and implementing fraud prevention plans

Identifying the causes of fraud and formulating a fraud prevention plan

The University considers the occurrence of misconduct to be a problem of the management system of research expenses at research institutions as well as a problem of the awareness of individual researchers, and has formulated the "Competitive Research Funds Misconduct Prevention Plan at Aoyama Gakuin University" and is making efforts to implement the plan throughout the University.
We believe that it is important for researchers to be fully aware of the significance of research and its social impact, and to conduct their research activities with a sense of ethics, without having the mistaken perception that the funds were secured by individual researchers, even though the funds are tax-funded competitive research funds.
In addition, we believe it is important to create an environment that systematically nips "misconduct" in the bud, based on the recognition that misconduct may occur even when unintentional.
Research Support Department and Sagamihara Campus Administration Department Research Promotion Division are the departments in charge of promoting the Fraud Prevention Plan from the perspective of the entire research institution.
The Misconduct Prevention Plan will be reviewed periodically for more effective implementation of misconduct prevention activities by the Chief Administrative Officer and the department in charge of promoting the Misconduct Prevention Plan under the Chief Administrative Officer, President.

Aoyama Gakuin University 's Plan to Prevent Fraudulent Use of Competitive Research Funds

Appropriate management and administration of research funds

Until March 31, 2013, Article 10 of the "Aoyama Gakuin University Internal Regulations Regarding the Use of Public Research Funds" stipulated that "In the case of the purchase of items with a price of 50,000 yen or more per item or per set, or items with a price of 200,000 yen or more per purchase, an inspection of the delivered goods will be required." Therefore, only items that met this price limit were subject to inspection. However, from April 2013, the price limit was lifted, and all items costing 1 yen or more and paid for using all Aoyama Gakuin University 's budget are now subject to inspection.
Additionally, as a policy for taking disciplinary measures such as suspending transactions with businesses involved in fraudulent transactions, Article 33 (Dealing with businesses involved in fraud) of the "Aoyama Gakuin University Detailed Rules Regarding Responding to Misconduct in the Use of Public Research Funds" stipulates that "When a business is found to be involved in the fraudulent activity, we will file a claim for damages against the business, and will take disciplinary measures such as suspending transactions depending on the content and seriousness of the fraud."
Research Support Department and Sagamihara Campus Administration Department Research Promotion Division will endeavor to establish rules and regulations and hold information sessions to disseminate information and raise awareness.
Additionally, under the instructions of the Chief Management Officer and the implementation plan formulated by the General Management Officer, compliance training etc. will be conducted to raise awareness regarding the appropriate use of research funds.

[To business partners (Request for submission of written pledge)]

Based on the "Guidelines for the Management and Audit of Public Research Funds at Research Institutions (Implementation Standards)" established by the Ministry of Education, Culture, Sports, Science and Technology, our university requires vendors who have a certain record of doing business with our university to submit a pledge that they will abide by our university's internal rules and will not be involved in improper transactions as a measure to prevent the unauthorized use of research funds.
We ask that you understand this purpose and submit the pledge.

Inspection activities

Through collaboration between Research Support Department, the Research Promotion Division Sagamihara Campus Administration Department, and Audit Office, we will conduct effective monitoring and internal audits of competitive research funds.
Research Support Department and Sagamihara Campus Administration Department Research Promotion Division will endeavor to inspect and verify the execution of research funds from an institution-wide perspective by conducting audit activities such as individual monitoring of business operations.
In addition, in order to make the verification and inspection function of research funding execution more effective, in addition to the individual monitoring mentioned above, audits will be conducted by Audit Office Aoyama Gakuin School Corporation, and if necessary, external audits will be conducted by certified public accountants by Aoyama Gakuin School Corporation.
In addition, Article 19 (Publication of Audit Results) of the "Aoyama Gakuin University Rules Concerning the Implementation System for the Management, etc. of Public Research Funds" stipulates that the results of audits will be made public to researchers in order to deepen understanding of the proper use of research funds.