All 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 and refrain from
any fraudulent or financially improper activity.
Fraud and financial impropriety shall include but not be limited
1. Forgery or unauthorized alteration of any document or account
belonging to the District.
2. Forgery or unauthorized alteration of a check, bank draft,
or any other financial document.
3. Misappropriation of funds, securities, supplies, or other
District assets, including employee time.
4. Impropriety in the handling of money or reporting of District
5. Illegally or inappropriately profiting as a result of insider
knowledge of District information or activities.
6. Unauthorized disclosure of confidential or proprietary
information to outside parties.
7. Unauthorized disclosure of investment activities engaged
in or contemplated by the District.
8. Accepting or seeking anything of material value from contractors,
vendors, or other persons providing services or materials
to the District, except as otherwise permitted by law or District
9. Inappropriately destroying, removing, or using District
records, furniture, fixtures, or equipment.
10. Failure to provide financial records required by state
or local entities.
11. Failure to disclose conflicts of interest as required
by law or District policy.
12. Any other dishonest act regarding the finances of the
The Superintendent or designee shall be responsible for developing
and implementing internal controls designed to prevent and
detect fraud, financial impropriety, or fiscal irregularities
within the district.
The system of internal controls shall identify potential risks,
evaluate the nature and extent of those risks, and manage
Any person who suspects fraud or financial impropriety in
the District shall report the suspicions immediately to the
Superintendent or designee, the Board Chair, or local law
enforcement. Neither the Board nor any District employee shall
unlawfully retaliate against a person who in good faith reports
perceived fraud or financial impropriety.
In coordination with legal counsel and other internal or external
departments or agencies, as appropriate, the Superintendent
or designee shall promptly investigate reports of potential
fraud or financial impropriety. If the Superintendent is involved
in the complaint, the School Board Chair is authorized to
initiate investigation of the complaint and coordinate the
investigative efforts with individuals and agencies s/he deems
Reports of suspected fraudulent activities shall be investigated
in a manner that protects the confidentiality of the parties
and avoids unfounded accusations. Employees involved in the
investigation shall be advised to keep information about the
If an investigation substantiates a report of fraud or financial
impropriety, the Superintendent or designee shall promptly
inform the Board of the report, the investigation, and any
responsive action taken or recommended by the administration.
If an employee is found to have committed fraud or financial
impropriety, the Superintendent or designee shall take or
recommend appropriate disciplinary action, which may include
termination of employment. If a contractor or vendor is found
to have committed fraud or financial impropriety, the District
shall take appropriate action, which may include cancellation
of the District’s relationship with the contractor or
When circumstances warrant, the Board, Superintendent, or
designee may refer matters to appropriate law enforcement
or regulatory authorities. In cases involving monetary loss
to the District, the District may seek to recover lost or
The final disposition of the matter and any decision to file
a criminal complaint or to refer the matter to the appropriate
law enforcement or regulatory agency for independent investigation
shall be made in consultation with legal counsel.
ADOPTED: 26 February 2009