Jerome Joint School District No. 261

FINANCIAL MANAGEMENT 7225

Financial Fraud and Theft Prevention

Disclaimer:

District Financial Fraud or Theft is a criminal matter and covered by State laws. This policy is merely a guideline so

that all District employees understand the possible repercussions of such actions. If you have questions regarding

fraud and/or theft, please contact your District legal counsel and/or your local law enforcement agency.

All District employees, board members, consultants, vendors, contractors and other parties maintaining a business

relationship with the District shall act with integrity and due diligence in matters involving district fiscal resources.

The Superintendent shall be responsible for developing internal controls designed to prevent and detect fraud,

financial impropriety or fiscal irregularities within the District. Every members of the district’s administrative team

shall be alert for any indication of fraud, financial impropriety or irregularity within his/her areas of responsibility.

The superintendent shall investigate reports of fraudulent activity in an manner that protects for confidentiality of

the parties and the facts. All employee involved in the investigation shall be advised to keep information about the

investigation confidential. While investigating and responding to the financial fraud allegations, the

Superintendent or Chair of the Board will give priority to avoiding possible retaliation or reprisals.

Staff Responsibilities

Any employee who suspects that financial fraud, impropriety or irregularity has occurred shall immediately report

those suspicions to their immediate supervisor and/or the Superintendent/designee who shall have the primary

responsibility for initiating necessary investigations. Additionally, the Superintendent shall coordinate investigative

efforts with the District’s legal counsel, auditing firm and other internal or external departments and agencies,

including the county prosecutor’s office and law enforcement officials, as the Superintendent may deem

appropriate.

An employee who believes they have suffered reprisal, retaliation, or discrimination for a report under this policy

shall report the incident(s) to the Superintendent/designee. The Board will attempt to ensure that no employee

who makes such a report will suffer any form of reprisal, retaliation, or discrimination for making the report.

Employees are prohibited from preventing or interfering with those who make good faith disclosures of

misconduct. This policy shall not apply when an employee knowingly makes a false report.

In the event the concern or compliant involves the Superintendent, the concern shall be brought to the attention

of the Chairman of the board of Trustees who is hereby empowered to contract the district’s legal counsel,

auditing firm and any other agency to investigate the concern or compliant.

Definition

As used in this policy, “fraud” refers to intentionally misrepresenting, concealing or misusing information in an

attempt to commit fiscal wrongdoing. Fraudulent actions includes, but are not limited to:

•  Behaving in a dishonest or false manner in relation to District assets, including theft of funds, securities,

supplies or other District properties.

•  Forging or altering financial documents or accounts illegally or without proper authorization.

•  Improper handling or reporting of financial transactions

•  Personally profiting as a result of insider knowledge

•  Disregarding confidentially safeguard concerning financial information

•  Violating board conflict of interest policies

•  Mishandling financial records of district assets (destroying, removing or misusing)

Internal controls

The following internal controls shall be a regular practice of the district in an effort to prevent the possibility of

fraud.

•  Budgetary Transfers. The transfer of appropriations is important for the superintendent, purchasing

agent, business official and treasurer, and all should have written confirmation of the information. The

purchasing agent shall be apprised of the transfer has been approved, the treasurer shall document it and

the business office shall record it.

•  Treasurer’s Receipts. The treasurer should have receipts and numbered duplicates for everything paid

out in his/her custody.

•  Check. The treasurer shall keep personal custody of any signature stamps and maintain a log for every

check written.

•  Audit. An individual not connected to the business office should audit the check register regularly.

•  Conduct background checks on potential business office employees. Check all possible references, not

just those offered, and perform criminal background checks on key business officials and other warranted.

•  Segregate functions within the business office so as to avoid the opportunity for fraud without collusion.

Policy History:

Adopted on: 11/21/2006

Revised on: 12/18/2013