[IMPORTANT] Proper Use of Research
Researchers may be subject to disciplinary action from Keio University and the funding agency, or face legal action
or criminal proceedings for the improper use or allotment of research funds.* The impact such actions have on Keio
University are also immeasurable, including disciplinary action and loss of credibility with the funding agency. You may
also be held liable and subject to disciplinary action not only when you are deemed intentionally implicated in suchacts, but even in cases stemming from negligence, such as accounting errors or an insufficient grasp of the rules forthe use of funds, or cases in which, while willful involvement in the improper use or allotment of research funds is notdetermined, a lack of due diligence is evidenced. It is important to be aware that most cases involve a lack ofunderstanding of the rules or having neglected to properly manage funds leading to unintended situations, therefore,
ensure that you consult with the administrative staff in charge regularly to confirm the various rules regarding usage.
The following is an example of improper use or allotment of research funds. We also encourage individual researchers
to exercise due caution and continue to properly use research funds to prevent such cases from occurring.
* “Improper use or allotment of research funds” refers to the use of research funds for purposes other thanresearch, or use that violates the terms of conferral or the conditions therein.

1. Primary examples of improper use or allotment of research funds■ A falsified order or purchase of goods (fraudulent deposits, artificially inflating charges, tampering with productnames)
The act of having a supplier claim a deposit for a non-existentor dishonest transaction, and having the funds handled
as a deposit by the supplier. Examples include:
1) Forging falsified accounting documents in the guise of purchasing goods, temporarily taking receipt of the goods
from the supplier to pass delivery inspections, and having the paid funds handled as a deposit by the supplier.
2) Increasing the charge amount by purchasing goods at a higher price than usual, and then having the suppliertransfer the balance to your bank account.
3) Placing orders using accounting documents rewritten to list a different product name from the actual goods
delivered, and having the vendor forge and issue fraudulent delivery slips.

■ Fraudulent remuneration and honoraria
The act of claiming for a wage or honoraria through desceptive means. Examples include:
1) Claiming for an honoraria to compensate non-existent work that has not actually been completed in order tosupport student living expenses.
2) Fabricating and submitting dishonest timesheets for students who are not actually working in order to make aclaim appear related to expenses required for the maintenance and operation of laboratories.
3) Neglecting to properly allocate financial resources or duty management, such that payment of remuneration is
not based in one’s actual work or is outside the bounds of the purpose of the research funding.

■ Fraudulent business trips
Fraudulently claiming expenses for a business trip. Examples include:1) Submitting applications for different routes/means of transportation than those actually used and claiming thebalance.
2) Falsifying or tampering with invitation emails (date and time, contents, etc.) from the inviting party as a reason
to undergo a business trip unrelated to the purpose of one’s research.
3) Going on a trip related to one’s own private corporation and not for the purpose of the research funds, or also
unnecessarily creating work related to the research funds while on such a trip, and then claiming the full amountas travel expenses for a research business trip.

■ Double billing
The act of receiving double payments, such as by claiming expenses for business trips, etc., for which travel expenses
have already been paid by another institution. Examples include:
1) Concealing the fact that travel expenses have already been paid by the hosting corporation of a seminar, etc.,
and charging those expenses to Keio.
2) Printing multiple copies of digital receipts and invoices and billing them to separate funds.

2. Primary examples of improper conduct
Inappropriate conduct such as engaging in money pools*1 or behavior to recollect funds*2 are strictly prohibited.
Inappropriate conduct may also be subject to the disciplinary action indicated in 3. below.
*1 Money pools
The act, for what ever reason, of a laboratory or individual appropriating the difference, etc., generated by improperuse or allotment of research funds.
*2 Recollecting funds
The act of collecting all or part of wages, honoraria, or travel expenses once they have been paid to students, etc.,
for private use, or expenses required for the maintenance or operation of laboratories.
Such acts are deemed unacceptable even with the consent of the student, etc.

3. Disciplinary action for the wrongful use or allotment of research funds■ Disciplinary action for individual researchers
・ Consequences with Keio
Should the Research Compliance Committee determine the disciplinary actions stipulated in the Regulations for
Rewards and Punishments (Employment) to be appropriate following an investigation into the person who wrongfully
used or allocated research funds, depending on the severity and nature of the misuse, a disciplinary order of a
reprimand, reduction in salary, suspension of employment, request for resignation, or disciplinary dismissal may beissued by the President.
(See Rules for Disciplinary Action Appeals for Unauthorized Use of Public Funds)
・ Disciplinary action by the funding agency
i. Restriction of application eligibility
Funding agencies will limit the application and eligibility for competitive funds for up to 10 years.
(See Guidelines for Proper Execution of Competitive Funds [Agreement by the relevant ministries andagencies regarding competitive funds])
ii. Return of funds
Should research funds be improperly used or allotted, their conferral may be revoked by the funding
agency, and the researcher who wrongfully used or allocated research funds will be held liable for returning
the funds. (Article 8 of the Regulations Regarding Use of Public Funds)
In some cases, an additional fee will be added to this at an annual rate of 10.95% from the date the researchfunds were received, and a late fee for non-payment calculated at a 10.95% annual rate from the date thepayment is missed. (See Chapter 4 of Act on Regulation of Execution of Budget Pertaining to Subsidies. If
the subsidy is from a government agency other than the national government, check the ordinances andrules. If you have a contract, check the contract details.)
・ Legal action
You may be subject to legal action such as criminal charges and civil proceedings from universities and funding
agencies. (See Rules for Disciplinary Action Appeals for Unauthorized Use of Public Funds)

・ Criminal punishment
Many malicious cases are treated as crimes of fraud.

■ Consequences and impact on research institutions
・ The offender may be liable to return the amount of wrongfully used or allotted research funds, etc.
・ Measures may be implemented to reduce indirect expenses for research institutes
・ Loss of credibility as an institution
・ Huge time and cost burdens borne by the institution for the fraud investigation* Detailed rules regarding the use of research funds can be found at the following URL.
https://www.research.keio.ac.jp/internal/forms/01.html (Accessible only via the campus network)