The Lyme School •  Lyme, New Hampshire
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Policy Manual

Policy: DIF
Fraud Prevention

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 to:

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 financial transactions.

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 policy.

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 District.

Fraud Prevention

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 them effectively.


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 appropriate.

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 investigation confidential.


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 vendor.

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 misappropriated funds.

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