INTRODUCTION o DISCUSS ADOPTION OF FRAUD AND THEFT POLICY o ASSIGNS RESPONSIBILITY FOR REPORTING FRAUD AND THEFT o PROVIDES GUIDELINES FOR INVESTIGATIONS OF SUSPECTED FRAUD OR THEFT o FRAUD AWARENESS TRAINING REQUIREMENTS o CONSEQUENCES - READ THE POLICY o FRAUD, THEFT (AND WHISTLEBLOWER) HOTLINE AND WEBSITE
DEFINITIONS WHAT ARE SOME EXAMPLES OF FRAUD? Forgery or alteration of a check, bank draft, or any other financial document Theft of a check or other diversion of a payment made to the city Improper or dishonest handling of funds, supplies or other assets Improper handling or reporting of financial transactions Profiteering as a result of insider knowledge of City operations Selling or using confidential City information in the conduct of an outside business activity
DEFINITIONS WHAT ARE SOME EXAMPLES OF THEFT? The act of taking something from someone unlawfully Taking equipment or supplies belonging to the City and keeping it for personal use Improper use of employee purchasing privileges (for example: using ID card for personal use)
AUDITOR QUESTIONNAIRE: DISCUSS QUESTIONNAIRE - Sent to financial managers & to randomly selected employees
RESPONSIBILITY TO REPORT FRAUD EMPLOYEES OR VOLUNTEERS: IF YOU SUSPECT FRAUD OR THEFT, WHAT DO YOU DO? o REPORT TO SUPERVISOR OR ETHICS OFFICER (WHO IS THE ETHICS OFFICER ?) CITY ATTORNEY o THE SUPERVISOR DOES NOT HAVE THE AUTHORITY TO DETERMINE THE MERITS OF A REPORT OF KNOWN OR SUSPECTED FRAUD OR THEFT; ONLY THE ETHICS OFFICER MAKES THIS DETERMINATION; SUPERVISORS SHOULD MAKE REPORTS TO THE ETHICS OFFICER FOR FURTHER INVESTIGATION IDENTITY OF COMPLAINANT WILL BE PROTECTED TO THE FULL EXTENT ALLOWED BY LAW -anonymous reporting makes this point moot (debatable) ANY FORM OF RETALIATION AGAINST COMPLAINANT WILL NOT BE TOLERATED ELECTED OFFICIALS: IF YOU SUSPECT FRAUD OR THEFT, WHAT DO YOU DO? o REPORT TO ETHICS OFFICER OR CITY MANAGER
GUIDELINES DO NOT CONTACT THE SUSPECTED INDIVIDUAL ALLOW THE ETHICS OFFICER TO CONDUCT THE INVESTIGATION OBSERVE STRICT CONFIDENTIALITY - DO NOT DISCUSS WITH ANYONE OTHER THAN YOUR SUPERVISOR OR THE ETHICS OFFICER o Progress of investigation can be accessed by use of a confidential code system
RESPONSIBILITIES OF THE ETHICS OFFICER AND GUIDELINES FOR THE INVESTIGATION CONDUCT THE INVESTIGATION, DETERMINE IF THE REPORT IS CREDIBLE AND DOCUMENT THE RESULTS MAKES EVERY EFFORT TO PROTECT THE IDENTITY OF THE PERSON WHO, IN GOOD FAITH, REPORTED THE SUSPECTED FRAUD
DISCIPLINARY ACTION WILL BE TAKE IF: EMPLOYEE ENGAGES IN FRAUD OR THEFT EMPLOYEE SUSPECTS OR DISCOVERS FRAUD AND FAILS TO REPORT -could give the appearance of complicity EMPLOYEE INTENTIONALLY REPORTS FALSE OR MISLEADING INFORMATION
FRAUD AWARENESS TRAINING ALL EMPLOYEES ARE REQUIRED TO ATTEND FRAUD AWARENESS TRAINING AT LEAST ONCE EVERY THREE YEARS ALL EMPLOYEES IN FINANCIAL POSITIONS MUST HAVE TRAINING EVERY YEAR ANNUAL REPORT INCIDENTS REPORTED TO AUDIT COMMITTEE WHISTLEBLOWER POLICY FRAUD HOTLINE AND WEBSITE: THE WHISTLEBLOWER POLICY COVERS SEVERAL OTHER AREAS IN ADDITION TO THEFT AND FRAUD –hand out bill-fold card, and HR director information on other areas of reporting
Questions and answers: Speak Up for rCity Values of Integrity and Respect Report Suspected Fraud or Theft Telephone: Website: Reports are confidential Log in to report behaviors that violate the law and rCity values. Harassment or discrimination Threats or violence Theft or fraud; accounting or financial irregularities Violations of laws or regulations On-the-job drug or alcohol abuse It’s easy, confidential, and always available!