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Anti-Fraud Policy
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PURPOSE The purpose of this policy is to provide guidelines for the prevention, deterrence, and detection of fraud.  Administration and Staff will be responsible for creating a positive workplace environment ensuring a culture of honesty and ethical behavior to enhance Comal ISD’s ability to protect its assets, operations, and reputation.
SCOPE This policy applies to any fraud, or suspected fraud, involving employees, consultants, vendors, contractors, and/or any other party with a business relationship with the District.  All employees are responsible for the detection and prevention of fraud, misappropriations, and other irregularities.  Each administrator shall be familiar with the types of improprieties that might occur within his or her area of responsibility, and be alert for any indication of fraud.
Any fraud that is detected or suspected must be reported immediately to the District’s Internal Auditor, who shall coordinate all investigations.  All employees will be held accountable to act within the organization’s code of conduct.
ACTIONS CONSTITUTING FRAUD Fraud is defined as the intentional false representation or concealment of a material fact for the  purpose of inducing another to act upon it to his or her injury.  Examples of fraud refer to, but are not limited to:
  1)Any dishonest or fraudulent act

2) Impropriety in the handling or reporting of money or financial transactions

3) Forgery or alteration of any document or account belonging to the District (checks, timesheets, invoices, contractor agreements, bid documents, purchase orders, electronic files, and other financial documents)

4) Forgery or alteration of a check, bank draft, or any other financial document

5) Financial report misrepresentation

6) Misappropriation of funds, securities, supplies, inventory, or any other asset including furniture, computers, fixtures or equipment)

7) Authorizing or receiving payments for hours not worked

8) Disclosing confidential and proprietary information to outside parties

9) Accepting or seeking anything of material value from contractors, vendors, or persons providing services/materials to the District that may be construed to be an attempt to influence the performance of an employee’s official duty in the scope of employment for the District

10) Destruction, removal, or inappropriate use of records, furniture, fixtures and equipment

11) Any similar or related irregularity

  Questions as to whether an action constitutes fraud should be referred to the District’s internal auditor for clarification.
REPORTING FRAUD Comal ISD expects employees and others with serious concerns about any aspect of Comal ISD’s ongoing operations to come forward and voice those concerns.  Concerns should be reported in writing using the fraud disclosure form that will be available for all employees.  This form encourages individuals to put their names to allegations, but is not a requirement.  If an allegation is made in good faith, but is not corroborated by the investigation, no action will be taken against the originator of the allegation.  If individuals make malicious allegations, disciplinary action may be considered against that individual.
  Individuals can also call the Internal Auditor directly.
  Comal ISD realizes that the originator of the complaint needs to be assured that the matter has been properly addressed.  To help with this, whenever appropriate, and subject to legal constraints, the originator of the complaint will receive information about the outcome of any investigation.
INVESTIGATION RESPONSIBILITIES The Internal Auditor shall have the primary responsibility for the investigation of all suspected fraudulent acts as defined in this policy.  Any employee who suspects dishonest or fraudulent activity must notify the Internal Auditor immediately.  An employee shall not attempt to personally conduct investigations and shall not contact the suspected individual in an effort to determine facts of demand restitution.
  Upon completion of its investigation, the Internal Auditor shall submit a report detailing its findings to the Superintendent, the Board President, and to other administrators and Board of Trustee members, as appropriate.  The Internal Auditors report may contain a recommendation to refer the matter to the appropriate law enforcement and/or regulatory agencies for independent investigation.  The decision to make any such referral shall be made by the Superintendent, or the Board of Trustees, in conjunction with legal counsel.
CONFIDENTIALITY The Internal Auditor shall treat as confidential all reports of suspected fraud or irregularities and all information obtained through an investigation.  Comal ISD will attempt to protect an individual’s identity if they report a concern and do not want their name disclosed.  The investigation process, however, may reveal the source of the information, and/or a statement by the individual may be required as part of the evidence.  Comal ISD will not tolerate harassment or victimization and will take action to protect those who raise a concern in good faith.
  Investigation results shall not be disclosed or discussed with anyone other than those who have a legitimate need to know.  All inquiries concerning the activity under investigation from the suspected individual, his attorney or representative, or any other inquirer should be directed to the Internal Auditor.
AUTHORIZATION In the course of an investigation of suspected fraud, with proper notification of the appropriate level of management and in the presence of the appropriate administrator, the Internal Auditor shall have:
 

1) Free and unrestricted access to all District records, premises, and facilities, whether owned or rented by the district

2) The authority to interview employees

3) The authority to examine, copy, and/or remove all documents, electronic data, files, tapes, disks, computers, and other equipment and storage facilities on the premises without prior knowledge or consent of any individual who may use or have custody of any such items or facilities when it is the scope of the investigation
CONSEQUENCES In the event an employee is found to be engaging in or to have been engaged in fraudulent acts, or failed to report fraudulent acts, he/she will be subject to disciplinary action, which could include termination.  Based on the seriousness of the offense, the results may be referred to the appropriate law enforcement and/or regulatory agencies.

 
 
 
 

©2005 Comal Independent School District