Established on September 5, 2014
Last revised on May 13, 2022
Standards for Implementation of Management and Audits of Public Research Funds at Tokyo
International University

As a rule, competitive research funds are granted to individual researchers or groups of researchers.
Because the source of funding is dependent on the tax burden of the nation's people, the funds must
be used appropriately, effectively, and with discipline in order to respond to the expectations andtrust of the people. Accordingly, the management of competitive research funds, etc., shall be
conducted under the responsibility of Tokyo International University (hereinafter "TIU"), in a
uniform and comprehensive manner, rather than leaving the management of such competitive
research funds, etc., solely to the researchers who acquired them. To achieve this aim, the Standards
for Implementation of Management and Audits of Public Research Funds at Tokyo International
University shall be established as follows in accordance with the stipulations of “Guidelines forManaging and Auditing Public Research Funds at Research Institutions” (adopted by MEXT on
February 15, 2007, revised on February 1, 2021; hereinafter "MEXT Guidelines").

Section 1 Internal Responsibility Hierarchy
1. Responsibility hierarchy for the operation and management of competitive research funds, etc.
In order to operate and manage competitive research funds, etc., appropriately, the responsible
person at each level shall be established as follows, and the job titles shall be published on the TIU
website.
(1) Person with final managing responsibility for operation and management of competitive researchfunds, etc.
Job title: University president
Responsibilities: Oversee the entire university, and bear final responsibility for the operation andmanagement of competitive research funds, etc.
Roles: a. Formulate basic policy to prevent misconduct, ensure that it is communicated to therelevant parties, and devise necessary measures to implement the policy. In addition, the chief
executive displays appropriate leadership to enable the chief administrator and the person
responsible for promoting compliance to responsibly operate and manage competitive researchfunds, etc.

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b. When formulating the basic policy for misconduct prevention measures and creating concrete
misconduct prevention measures, deepen discussions regarding the status of implementation and theeffectiveness, etc., with other officers, etc., at the Executive Meeting.
c. The President encourages efforts to prevent misconduct, etc., through attendance at faculty
meetings, etc., and otherwise periodically conducts a variety of educational activities in an effort toincrease and spread the awareness of the parties.
(2) Chief administrator
Job title: Chief Administrative Officer
Responsibilities and authority: The Chief Institutional Affairs Officer shall assist the President andshall have the responsibility and authority to oversee the operation and management of competitive
research funds, etc., throughout TIU in a cross-organizational manner.
Role: Formulate and implement university-wide measures to prevent misconduct, confirm the statusof implementation, and report to the President.
(3) Person responsible for promoting compliance
Job title: Senior Manager of the General Administration and Academic Subsidies Office,Institutional Affairs and Academic Subsidies Department
Responsibilities and authority: The person responsible for promoting compliance shall have thepractical responsibility and authority to operate and manage competitive research funds, etc., at TIU.
Role: The individual shall have the following roles under the direction of the chief administrator.
a. Implement university-wide measures to prevent misconduct, confirm the status of implementation,and report to the chief administrator.
b. To prevent misconduct, all parties at TIU involved in the operation and management ofcompetitive research funds, etc., at TIU shall be provided with compliance education, and the statusof undergoing that education shall be managed and overseen.
c. Educational activities shall be conducted periodically at TIU.
d. Parties at TIU shall be monitored to determine whether they are managing and executing
competitive research funds, etc., appropriately, and instructions for improvement shall be given asnecessary.
2. The Role of Auditors(1) Auditors shall confirm the status of establishment and operation of internal control related to theprevention of misconduct, from a university-wide perspective, and shall offer their opinions
regarding the matters.
(2) In particular, auditors shall confirm whether factors resulting in misconduct that have been2

identified through monitoring and internal audits conducted by the chief administrator or the person
responsible for promoting compliance have been reflected in the misconduct prevention plan, andwhether the misconduct prevention plan is being implemented appropriately, and shall offer theiropinions regarding the matters.

Section 2 Establishment of an Environment to Serve as a Foundation forAppropriate Operation and Management
The President shall strive to eliminate factors that invite misconduct, and shall establish anenvironment and structure with sufficient preventive functions, on the assumption that there isalways a possibility that competitive research funds, etc., will be used inappropriately.
1. Implementation of compliance education and training activities (Raising and permeation of theawareness of relevant parties)(1) The person responsible for promoting compliance shall implement compliance education for allparties related to operation and management of competitive research funds, etc., in accordance withthe stipulations of the implementation plan that was formulated by the chief administrator.
(2) The contents of compliance education shall be effective and viable, and shall be set according to
the duties and the authority/responsibilities of each party. The contents shall be reviewed and revised
periodically.
(3) When conducting the education, a regular schedule for undergoing the training shall be set inadvance and the status of training and the understanding gained by the trainees shall be monitored.
(4) When the training is conducted, all parties related to the operation and management ofcompetitive research funds, etc., shall be required to submit a written pledge, etc., that includes thefollowing, in order to enable the relevant parties to understand that they have an obligation tocomply with the contents, and to spread an awareness of the matter. The written pledge, etc., shall bea requirement to apply for competitive research funds, etc., and if it is not submitted, the individual
shall not be allowed to participate in operation and management of competitive research funds, etc.
(a)Commitment to comply with the rules and regulations, etc., of TIU(b)Commitment to refrain from misconduct(c)Commitment to accept the actions of TIU and organizations distributing competitive researchfunds, etc. (organizations defined in "MEXT Guidelines" "Terminology" (3)) and related legal
responsibility in the event of misconduct in violation of rules and regulations, etc.
(5) The person responsible for promoting compliance shall not only implement complianceeducation for all parties related to operation and management of competitive research funds, etc., in
accordance with the stipulations of the implementation plan that was formulated by the chief
administrator, but shall also implement continued educational activities aimed at eradicating3

misconduct.
(6) "Tokyo International University Foundation Code of Ethics" shall be positioned as the code of
conduct for all parties involved in the operation and management of competitive research funds, etc.
2. Clarification and standardization of rules"Tokyo International University Rules regarding Researchers Receiving Grants-in aid for Scientific
Research," "Tokyo International University Bylaws for Enforcement of the Rules regarding
Researchers Receiving Grants-in-aid for Scientific Research," and "Manual for Execution andClerical Work related to Grants-in-aid for Scientific Research" shall be used uniformly as the rules
and guides for clerical processing procedures related to competitive research funds, etc., at TIU.
Efforts shall be made to make researchers and students, etc., who receive payment of rewards, travel
expenses, etc., through competitive research funds, etc., at TIU thoroughly familiar with these rules,
etc., and the rules, etc., shall be reviewed continually to ensure that there are no discrepancies
between actual operation and the rules, etc.
3. Clarification of administrative authority(1) The Institutional Affairs and Academic Subsidies Department, General Administration andAcademic Subsidies Office shall be in charge of clerical work related to competitive research funds,
etc.
(2) The authority to make final decisions regarding clerical processing related to competitive
research funds, etc., shall conform to the stipulations of the "Tokyo International University Rules
regarding Collective Decision-making and the Authority to Make Final Decisions."
4. Handling and investigation of accusation, etc.; disciplinary action
The handling of accusations of misconduct related to competitive research funds, etc. (hereinafter"accusations, etc."), and the related procedures for investigation and disciplinary action, etc., shall be
as follows.
(1) The liaison for receiving accusations, etc., from both inside and outside TIU (identification of
misconduct from parties inside or outside TIU, self-reports, etc.) shall be the "Compliance Desk" ofthe Headquarters.
(2) In the event that accusations, etc., are received, the contents, etc., must be promptly reported to
the President via the person responsible for promoting compliance and the chief administrator.
(3) In the event that accusations, etc., are received, the reasonableness of the contents shall be
confirmed and a decision shall be made regarding the necessity of an investigation no later than 30days following reception, and the decision shall be reported to distributing organizations. This same
handling shall also apply to matters pointed out by media, the Board of Audit of Japan, or other4

outside organizations.
(4) If it is judged that an investigation is necessary, an investigative committee including third parties
from outside TIU (attorneys, certified public accountants, etc.) shall be formed to conduct theinvestigation. Third-party members of the investigative committee shall be those who do not have a
direct vested interest in TIU, the accuser, or the accused in the case. The investigative committee
shall conduct an investigation to determine whether there was any misconduct, the content of the
misconduct, the individuals involved, their degree of involvement, the monetary value of theunauthorized use, etc., and shall certify the findings.
(5) During the period until the certification stipulated in the preceding Item has been made, theaccused and other individuals under investigation shall be prohibited from using the competitive
research funds, etc., that are the target of the investigation, as necessary.
(6) When conducting the investigation of the relevant accusations, etc., reports shall be submitted tothe organizations distributing the competitive research funds, etc., related to the accusations, etc.,
and cooperation by the distributing organization shall be asked for in the investigation, as indicatedbelow.
(a) Reports and discussions regarding the investigation policy, investigation targets, and methods,etc.
(b)Investigation results, factors resulting in the misconduct, the status of the management andoversight structure for other competitive research funds, etc., with which individuals involved in the
misconduct are involved, submission of a final report including the plan to prevent recurrence(within 210 days after reception of the accusations, etc.; submission of an interim report if theinvestigation is not completed during the stipulated period)(c) Certification and report on any part of the alleged misconduct that is confirmed during the courseof the investigation(d) Submission of reports on the progress of the investigation and interim reports in addition to thepreceding Items, when requested by the distributing organization(e) Submission of materials related to the relevant accusations, etc., to the distributing organization,or inspection of the materials by the distributing organization, acceptance of an on-site investigationby the distributing organization (unless there is a justifiable reason, such as hindrance of theinvestigation)(7) The procedures for disciplinary action in the event that misconduct is certified as a result of theinvestigation of the accusations, etc., shall conform to the stipulations of Article 31 of the "Tokyo
International University Rules regarding Employment of Full-Time Faculty Members" and Article
39 of the "Tokyo International University Foundation Rules for Employment of Staff Members."

Section 3 Identification of Factors Leading to Misconduct and5Formulation/Implementation of Misconduct Prevention Plans
The President shall declare inside and outside TIU that the maximum effort will be exerted toprevent misconduct, and shall take responsibility to formulate plans to prevent misconduct, based ona systematic organization and evaluation of university-wide factors leading to misconduct. The
President shall take the initiative to manage the progress of the misconduct prevention plan.
1. Department In Charge of Promoting the Prevention Plan
(1) The department in charge of promoting the misconduct prevention plan from a university-wide
perspective (hereinafter "department in charge of promoting the prevention plan") shall be theInstitutional Affairs and Academic Subsidies Department, General Administration and Academic
Subsidies Office.
(2) The department in charge of promoting the prevention plan shall be partner with the chief
administrator to formulate/implement concrete measures (including misconduct prevention plans andcompliance education/training activities, etc., plans) throughout the entire organization, and confirm
the status of implementation.
(3) The department in charge of promoting the prevention plan shall strengthen collaboration withauditors, provide them with necessary information, etc., and shall establish opportunities to exchange
opinions regarding the status of formulation, implementation, and revision of the misconduct
prevention plan.
2. Identification of Factors Leading to Misconduct and Formulation/Implementation of Misconduct
Prevention Plans(1) The department in charge of promoting the prevention plan shall collaborate with the
Accounting and Finance Section of the Headquarters, which is in charge of internal audits related tocompetitive research funds, etc., to systematically organize and evaluate the status of the entire
University in terms of the forms and locations of factors leading to misconduct.
(2) The chief administrator and the department in charge of promoting the prevention plan shallformulate the misconduct prevention plan as the most important of the concrete university-widemeasures, in accordance with the stipulations of the basic policy for misconduct prevention measuresformulated by the President.
(3) When formulating the misconduct prevention plan, measures against factors that result in
misconduct that were identified in (1) above shall be reflected in the plan, and the contents shall be
viable. In addition, the plan shall be reviewed and revised as necessary according to the factors
leading to misconduct, and efforts shall be made to make it efficient and appropriate.
(4) Departments, etc., shall take the initiative to implement the misconduct prevention plan incooperation with the department in charge of promoting the prevention plan, in order to eradicate
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misconduct.

Section 4 Appropriate Operation and Management Activities for Research Funds
An appropriate budget shall be executed in light of the misconduct prevention plan stipulated in
Section 3. In addition, documents and data, etc., related to execution of research funds shall be
stored for a set period of time to enable verification at a later date. As the department in charge ofpromoting the prevention plan, the Institutional Affairs and Academic Subsidies Department,
General Administration and Academic Subsidies Office shall conduct the following activities forappropriate operation and management of competitive research funds, etc.
(1) Execution of budgets
i. Verify the status of execution of budgets by each researcher, regularly confirm that it matches theactual circumstances, and encourage the relevant researchers to make improvements if any problems
are found.
ii. Identify the sources of funds for expenditures at the order placement stage, and make it possible todetermine the status of execution of the budget without delay.
(2) Measures to prevent collusioni. Considering that improper transactions tend to occur when researchers and vendors have close
relationships, measures to prevent collusion shall be devised, such as suspension of business with thevendor involved in the improper transactions in accordance with Article 9 of the "Tokyo
International University Fixed Assets and Goods, etc., Procurement Regulations," or, as necessary,request that the vendor submit a written pledge after consideration of its effectiveness.
[Framework for written pledge contents]- Commitment to comply with the rules and regulations, etc., of TIU and to refrain from misconduct- Commitment to cooperate with requests for examination or submission of transaction ledgers
during internal audits and other investigations, etc.
- Commitment to refrain from objection to any and all actions, including suspension of business, inthe event that misconduct is verified- Commitment to report any requests from parties at TIU to engage in misconduct from a member,
etc.
ii. As a rule, ordering and inspection work shall be conducted by an administrative department, and asystem of checking by non-related parties shall be established and made to function effectively.
When conducting inspections, in addition to comparing the delivered items to the order data (orderforms, contracts, etc.), delivery shall be confirmed at the site after setup in the case of items that also
involve setup work, such as installation and adjustment.
(3) Otheri. As a rule, management of employment, such as confirmation of the work status of part-time7

employees, shall be conducted by an administrative department.
ii. Highly cashable goods shall be managed appropriately in accordance with their nature.
iii. A structure that enables administrative divisions to determine and confirm the status of executionof the business trip plans of researchers, etc., shall be established.

Section 5 Promotion of Information Transmission and Sharing
It can be assumed that not only the sharing of information inside TIU, but also the sharing of
information with other universities or outside organizations related to competitive research funds,
etc., are both necessary and effective in building, establishing, and maintaining an effective
misconduct prevention structure suited to TIU's scale and characteristics. With that in mind, thefollowing measures shall be devised.
(1) Establishment of a consultation service
The liaison for consultation from inside and outside TIU regarding rules, etc., related to the use ofcompetitive research funds, etc., at TIU shall be the Institutional Affairs and Academic Subsidies
Department, General Administration and Academic Subsidies Office, which shall be published tointernal and external parties via the TIU website, etc.
(2) External publication of policies for the prevention of misconduct, etc.
TIU's policy concerning the prevention of misconduct related to competitive research funds, etc., thecode of conduct, misconduct prevention plans, the management and operation structure, contacts forreporting of accusations, etc., shall be systemized, and the information shall be published to internaland external parties via the TIU website, etc.

Section 6 Monitoring
In an aim to effectively implement appropriate operation and management of competitive researchfunds, etc., and minimize the possibility of misconduct, a structure for effective monitoring from a
university-wide perspective suited to TIU's scale and characteristics shall be established as follows,
and efforts shall be made to strengthen the preventive function through dynamic implementation ofaudits in light of the misconduct risk factors indicated in the Appendix.
(1) When conducting internal audits related to competitive research funds, etc., based on the
stipulations of these Standards, each of the following departments responsible for auditing shall bepositioned under the direct jurisdiction of the President, and shall be granted effective authority andstrengthened.
(2) Internal audits from the perspective of accounting
Internal audits from the perspective of accounting shall be the responsibility of the Accounting and
Finance Section of the Headquarters, and shall be conducted a set number of times periodically eachyear regarding financial information to confirm the establishment, etc., of necessary requirements for8accounting document format, etc., in light of the applicable rules. In addition, the competitive
research funds, etc., management structure shall be inspected for problems.
(3) Internal audits from the perspective of systems and business
Internal audits of the effectiveness and efficiency of systems and work to prevent violation of rules
shall be handled by the Institutional Affairs and Academic Subsidies Department, General
Administration and Academic Subsidies Office, which is the department in charge of promoting theprevention plan. When conducting audits, effective risk approach audits shall be conducted utilizing
sampling and random inspections, etc., of risks that should be given priority attention in
management in light of TIU's characteristics, with the risks listed in Section 3 (2) "Notes on
Implementation (i)" of the separate MEXT Guidelines in mind.
(4) When conducting internal audits, auditing plans shall be reviewed and revised as necessary inlight of factors resulting in misconduct that have been identified through past internal audits andmonitoring conducted by the chief administrator and the person responsible for promoting
compliance, in order to increase efficiency and appropriateness. In addition, individuals withspecialized knowledge (certified public accountants, individuals with audit experience in otherorganizations, etc.) shall be utilized to increase the quality of internal audits.
(5) Collaboration with auditors and accounting auditors
Departments handling internal audits in the management and auditing of competitive research funds,
etc., shall engage in the relevant internal audits, strengthen collaboration with auditors andaccounting auditors, and give consideration to enabling implementation of efficient, effective, andmultifaceted audits. In addition, opinions shall be exchanged periodically regarding the status ofestablishment/operation of internal control related to prevention of misconduct at TIU, as well as
methods of monitoring and conducting internal audits, and the ideal nature of operation andmanagement of competitive research funds, etc.
Revision and Abolition
These Standards shall be revised or abolished by the Chancellor and Chair upon deliberation by the
Executive Meeting.
Supplementary Provisions
These revised Standards shall come into effect as of May 13, 2022.
Appendix- Discrepancies between the rules and the actual circumstances (researchers placing orders withoutauthority to do so, normalization of exception processing, etc.)- Final decision procedures are complex and assignment of responsibilities is unclear
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- Tendency of budgets to be executed at specific times- Occurrence of problems of non-payment to vendors- Departments/laboratories where competitive research funds, etc., tend to be focused, or that have
newly acquired large-scale competitive research funds, etc.
- Insufficient checking of transactions (Management of the transaction logs in administrative
departments andmanagement of information regarding selection of vendors are insufficient.
- Frequent transactions at the same laboratory with the same vendors for the same items; tendency toplace orders with vendors with which only specific laboratories have a track record of transactions orthat have newly begun transactions with specific laboratories- Insufficient inspection of special service agreements for database/program/digital contents creation,
device maintenance/inspection, etc.
- Loss of substance in inspection work and monitoring, etc. (Confirmation by acceptance stamp only,lack of thoroughness in confirmation of the actual items through post-sampling, etc.)- Delivered items taken by vendors when they leave and repeated use of delivered items in delivery
inspections- Management of employment, such as confirmation of the work status of part-time employees, isleft up to the laboratory- Insufficient procedures to confirm the fact of business trips, etc. (Checking for double payment,
confirmation with the business trip destination, etc.)- High reliance on individuals or insular workplace environments (accounting work being conducted
mainly by specific individuals, etc., long-term assignment to specific departments, inability to go
against the intentions of supervisors, etc.) and research environments in which it is difficult toimplement effective preventive measures (processing of ordering/inspection work, etc., within thelaboratory, isolated laboratories, etc.)10