HEBC-AP: Fraud Prevention & Investigation
The Board expects all employees, board members, consultants, vendors, contractors, and other parties maintaining any business relationship with the District to act with integrity, due diligence, and in accordance with all laws in their duties involving the District’s fiscal resources. The District is entrusted with public dollars and no person connected with the District should do anything to erode that trust.
The Superintendent or designee shall be responsible for developing internal controls designed to prevent and detect fraud, financial impropriety, or fiscal irregularities within the District. Every member of the district’s administrative team shall be alert for any indication of fraud, financial impropriety, or irregularity within his/her areas of responsibility.
Any employee who suspects fraud, impropriety, or irregularity shall report their suspicions immediately to his/her immediate supervisor and/or the Superintendent. The Superintendent shall have primary responsibility for any necessary investigations and shall coordinate investigative efforts with the district’s legal counsel, auditing firm, and other internal or external departments and agencies, including the Cass County Prosecutor’s Office and law enforcement officials, as the Superintendent may deem appropriate.
In the event the concern or complaint involves the Superintendent, the concern shall be brought to the attention of the President of the Board who shall be empowered to contact the district’s legal counsel, auditing firm, and any other agency to investigate the concern or complaint.
The Superintendent may elect to employ the district’s auditing firm to conduct a partial forensic/internal control/SAS99 audit annually or otherwise as often as deemed necessary. The Superintendent is authorized to order a complete forensic audit if, in his/her judgment, such an audit would be useful and beneficial to the District.
Fraud, financial improprieties, or irregularities include, but are not limited to:
- Forgery or unauthorized alteration of any document or account belonging to the District.
- Forgery or unauthorized alteration of a check, bank draft, or any other financial document.
- Misappropriation of funds, securities, supplies, or other assets.
- Impropriety in the handling of money or reporting of financial transactions.
- Profiteering because of “insider” information of district information or activities.
- Disclosing confidential and/or proprietary information to outside parties.
- Accepting or seeking anything of material value, other than items used in the normal course of advertising, from contractors, vendors, or persons providing services to the District.
- Destroying, removing, or inappropriately using district records, furniture, fixtures, or equipment.
- Failing to provide financial records to authorized state or local entities.
- Failure to cooperate fully with any financial auditors or investigators.
- Any other dishonest or fraudulent act involving district monies or resources.
The Superintendent shall investigate reports of fraudulent activity in a manner that protects the confidentiality of the parties and the facts. All employees involved in the investigation shall be advised to keep information about the investigation confidential.
If an investigation substantiates the occurrence of a fraudulent activity, the Superintendent, or Board President if the investigation centers on the Superintendent, shall issue a report to appropriate personnel and to the Board. The final disposition of the matter and any decision to file or not file a criminal complaint or to refer the matter to the appropriate law enforcement and/or regulatory agency for independent investigation shall be made in consultation with district legal counsel. The results of the investigation shall not be disclosed to or discussed with anyone other than those individuals with a legitimate right to know until the results are made public.
Adopted: 11/30/09
Reviewed: 22/22/22
Revised: 22/22/22