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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 Executive Officer: President
Aoyama Gakuin University Oversees the entire system and holds ultimate responsibility for the operation and management of research funds and related matters.

■ General Manager: General Affairs Officer Vice President
It assists the Chief Administrator and holds substantive responsibility and authority overseeing the operation and management of research funds and other Aoyama Gakuin University.

■ Compliance Promotion Officers: General Manager of Studies, Dean of Graduate School, Partial Center Director, Director, The University Administration
As the Compliance Promotion Officer, you have substantial responsibility and authority for the operation and management of research funds and other matters within the Aoyama Gakuin University faculties, graduate schools, secretariats, and others.
Furthermore, compliance promotion officers appoint deputy compliance promotion officers within their respective faculties, graduate schools, centers, and secretariats to supervise or supervise, establishing a system that enables effective management and supervision. This clarifies the scope of responsibility at each faculty, graduate school, and secretariat level.

■ Deputy Compliance Promotion Manager
Assist the Compliance Promotion Officer.
In University Administration, the Deputy Compliance Promotion Officer shall be the Administrative Affairs Department Manager, Administrative Affairs Department Accounting Division Manager, Administrative Affairs Department Facility Manager, and Sagamihara Campus Administration Department Manager, and others may be appointed by the Director, The University Administration, who is the Compliance Promotion Officer.

■ Fraud Prevention Plan Promotion Department: Research Support Department and Sagamihara Campus Administration Department Research Promotion Division
Aoyama Gakuin University Formulate and implement specific overall measures and check the status of implementation.

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

In accordance with our educational policies and university philosophy based on Christian faith, and in order to ensure the reliability and fairness of academic research of a public nature and to secure public trust in the university's academic research activities, Aoyama Gakuin University has established a code of conduct that sets forth standards for behavior (attitude) in carrying out research and other related 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

At Aoyama Gakuin University Aoyama Gakuin University, we have established "Internal Regulations Regarding the Use of Public Research Funds" and have made them known to all researchers and administrative staff. The overall management officer constantly reviews these regulations to ensure that an appropriate checking system is maintained, and consults on revisions to the regulations as necessary. In addition, each faculty has established a system to ensure compliance with the regulations through its respective faculty meetings.

Establishment of a system to ensure the transmission of information

Aoyama Gakuin University has created a "Handbook on Handling Grants-in-Aid for Scientific Research Expenditures," which is always available on the researcher information website (http://rs.aoyama.ac.jp/). In addition, we hold an information session for grant recipients around June each year, where the secretariat repeatedly explains the importance of institutional management and the need to comply with researcher usage rules, other relevant laws and regulations, and various internal university rules, in order to ensure that these are understood and followed.
For inquiries regarding the rules for the execution of public research funds, please contact Research Support Department, the Research Promotion Division Sagamihara Campus Administration Department, Accounting Division of the General Affairs Administrative Affairs Department, or Accounting Division of the Sagamihara Campus Administration Department.
In order to strictly address misconduct and to deter and promptly detect violations of laws and regulations, we have established a contact point (hereinafter referred to as the "contact point") within the Legal Affairs Section of the General Affairs Department Legal Affairs Division Department at the Corporate Headquarters (hereinafter referred to as the "Legal Affairs Section") to receive reports, information, or accusations (hereinafter referred to as "Legal Affairs Division etc.") regarding misconduct. Furthermore, we have also established a contact point for receiving reports, etc. outside of the Corporation.
For specifics, please refer to the "Contact Point for Reporting Misconduct in the Use of Public Research Funds" below.

The regulations stipulate that when a report or other information is received at the counter, the contents of the report or information must be promptly reported to the highest management officer through the overall management officer.
To protect those who report or accuse others through the contact point (hereinafter referred to as "whistleblowers") and those who provide information (hereinafter referred to as "information providers"), we have established confidentiality provisions to guarantee the anonymity of the names of whistleblowers and information providers (hereinafter referred to as "whistleblowers, etc.").
Furthermore, the rules stipulate that no one shall treat those who cooperate with the investigation (hereinafter referred to as "investigation collaborators") unfavorably for that reason, and that any person who treats others unfavorably for cooperating with the investigation shall be subject to disciplinary action or other appropriate measures in accordance with the employment regulations.

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 operation of investigations into misconduct are stipulated in the "Aoyama Gakuin University Regulations on Responding to Misconduct in the Use of Public Research Funds," which are divided into preliminary investigations, main investigations, and reinvestigations.
Furthermore, the same regulations clearly state that, regarding matters related to the investigation, those involved in Aoyama Gakuin University 's response to misconduct must respect the honor, privacy, and other human rights of those involved and must not disclose any secrets they have learned to others. It also clearly states that whistleblowers and other cooperating investigators must not be subjected to any disadvantageous treatment for cooperating with the investigation.
Furthermore, the same regulations stipulate the following measures to be taken by Aoyama Gakuin University in response to an investigation: "If the highest-ranking administrator is found to have committed misconduct, he shall promptly take corrective measures and measures to prevent recurrence." "If the highest-ranking administrator is found to have committed misconduct, such as misappropriation of funds, and deems it necessary, he shall take legal action." "If the highest-ranking administrator is found not to have committed misconduct, he shall take necessary measures to prevent any harm to the whistleblower, the subject of this investigation, and other related parties."

Developing and implementing fraud prevention plans

Identifying the causes of fraud and formulating a fraud prevention plan

Aoyama Gakuin University Therefore, recognizing that the causes of research misconduct stem not only from individual researchers’ attitudes but also from issues with research funding management systems at research institutions, we have formulated the “Aoyama Gakuin University ’s Plan to Prevent Misconduct in Competitive Research Funding,” and are working to implement this plan university-wide.
We believe it is important for researchers to fully recognize the significance and societal impact of their research—and to conduct their research with a strong sense of ethics—without falling into the misconception that competitive research grants, which are funded by taxpayer money, are funds secured solely by the individual researcher.
At the same time, recognizing that misconduct can occur even unintentionally, we believe it is important to systematically create an environment that nips “misconduct” in the bud.
Research Support Department Sagamihara Campus Administration Department and the Research Office (Promotion Division), as the departments responsible for promoting the research misconduct prevention plan from the perspective of the entire research institution, formulate and implement the research misconduct prevention plan as well as plans for education and training to prevent research misconduct.
Furthermore, under the leadership of the Chief Administrative Officer (President), these plans are periodically reviewed by the General Manager and the department responsible for promoting the research integrity plan to ensure the implementation of more effective research integrity measures.

Appropriate management and administration of research funds

Until March 31, 2013, Article 10 of the "Internal Regulations Concerning the Use of Public Research Funds Aoyama Gakuin University "Aoyama Gakuin University that "when purchasing items with a price of 50,000 yen or more per item or set, or items with a price of 200,000 yen or more per purchase, an inspection of the delivered goods shall be conducted." Only items meeting this price requirement were subject to inspection. However, from April 2013, the price limit was removed, and all items costing 1 yen or more, all expenditures made using the entire budget of Aoyama Gakuin University, are now subject to inspection.
Furthermore, as a policy for disciplinary action against companies involved in fraudulent transactions, Article 33 (Response to Companies Involved in Fraud) of the "Detailed Regulations on Handling Fraudulent Activities in the Use of Public Research Funds Aoyama Gakuin University" stipulates that, "If a company or other entity is involved in such fraudulent activity, a claim for damages will be filed against the company or other entity, and a suspension of transactions will be imposed in accordance with the nature and severity of the fraudulent activity."
Research Support Department and the Research Promotion Division Sagamihara Campus Administration Department will endeavor to improve regulations and other procedures, and will hold explanatory meetings for information dissemination and awareness-raising.
Furthermore, under the direction of the Chief Management Officer and the implementation plan formulated by the Overall Management Officer, compliance training and other measures will be implemented to improve awareness regarding the appropriate use of research funds.

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

In accordance with the "Guidelines for the Management and Auditing of Public Research Funds in Research Institutions (Implementation Standards)" established by the Ministry of Education, Culture, Sports, Science and Technology, Aoyama Gakuin University Aoyama Gakuin University requires vendors with a certain track record of transactions with Aoyama Gakuin University to submit a written pledge stating that they will comply with our internal regulations and will not be involved in any fraudulent transactions.
We kindly request that you understand the purpose of this and submit a written 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.