Internal control is the responsibility of all employees of the school District. The Superintendent, business manager and School Business Official/Board Secretary shall be responsible for developing internal controls designed to prevent and detect fraud, financial impropriety, or fiscal irregularities within the District subject to review and approval by the Board.  Administrators shall be alert for any indication of fraud, financial impropriety, or irregularity within the administrator’s area of responsibility.

Any employee who suspects fraud, impropriety, or irregularity shall report their suspicions immediately to his/her immediate supervisor, or the Superintendent.  The Superintendent shall have primary responsibility for any necessary investigations and shall coordinate investigative efforts with the Board’s legal counsel, auditing firm, and other internal or external departments and agencies, including law enforcement officials, as the Superintendent may deem appropriate.

Employees bringing forth a legitimate concern about a potential impropriety will not be retaliated against and those who do retaliate against such an employee will be subject to disciplinary action up to, and including, termination.

In the event the concern or complaint involves the Superintendent, the concern shall be brought to the attention of the Board Vice President, who shall be empowered to contact the Board’s legal counsel, insurance agent, auditing firm, and any other agency to investigate the concern or complaint.

Upon approval of the Board, the Superintendent, may contact the State Auditor or elect to employ the District’s auditing firm or State Auditor to conduct a complete or 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 the Superintendent’s judgment, such an audit would be useful and beneficial to the District.  The Superintendent, shall ensure the State Auditor is notified of any suspected embezzlement or theft pursuant to Iowa law.  In the event there is an investigation, records will be maintained for use in the investigation.  Individuals found to have altered or destroyed records will be subject to disciplinary action, up to, and including termination.

Approved:    September 2007
Reviewed:    November 2019
Revised:        December 2019

Fraud, financial improprieties, or irregularities, 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 fund, 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, investigators or law enforcement.
• 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 and/or an audit committee member, or Board Vice President if the investigation centers on the Superintendent, shall issue a report to the Board and appropriate personnel. 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.