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804.71 Internal Controls

The board expects all board members, employees, volunteers, consultants, vendors, contractors, students, and other parties maintaining any relationship with the district to act with integrity, due diligence, and in accordance with all laws in their duties involving the district’s resources. The board is entrusted with public dollars and no one connected with the district should do anything to erode that trust.

All district employees are responsible for adhering to district-established internal controls. The superintendent and Chief Financial Officer (CFO) shall develop internal controls designed to prevent and detect fraud, financial impropriety, and/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, and/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 and to the CFO.

Fraud, financial improprieties, or irregularities include, but are not limited to:

  • Forgery and/or unauthorized alteration of any document and/or account belonging to the district.
  • Forgery and/or unauthorized alteration of a check, bank draft, and/or any other district financial document.
  • Misappropriation of district funds, securities, supplies, and/or other assets.
  • Impropriety in the handling of district monies and/or reporting of financial transactions.
  • Profiteering because of “insider” information related to district information and/or activities.
  • Disclosing confidential and/or proprietary district information to outside parties.
  • Accepting and/or seeking anything of material value, other than items used in the normal course of advertising, from contractors, vendors, and/or persons providing services to the district.
  • Destroying, removing, and/or inappropriately using district records, furniture, fixtures, and/or equipment.
  • Failing to provide district financial records to authorized state and/or local entities.
  • Failure to cooperate fully with any financial auditors, investigators and/or law enforcement in district-related matters.
  • Any other dishonest and/or fraudulent act involving district monies or resources.

The CFO shall have primary responsibility for any necessary investigations into alleged violations of this policy and shall coordinate investigative efforts with the district’s legal counsel, auditing firm, Office of the Auditor of the State of Iowa, and other internal and/or external departments and/or agencies, including law enforcement officials, as the superintendent may deem appropriate.

The investigation of fraudulent activity shall, to the extent permitted by law and policy, be conducted in a manner that protects the confidentiality of the parties and the facts. All employees involved in an investigation into an alleged violation of this policy shall be advised to keep information about the investigation confidential. If an investigation substantiates the occurrence of  a violation of this policy, the CFO shall make 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 and/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 (as determined by district legal counsel) until the results are made public.

Employees bringing forth a legitimate concern about a potential impropriety shall not face retaliation for raising these concerns; anyone who retaliates against such an employee shall be subject to disciplinary action up to, and including, termination.

In the event the concern or complaint involves the superintendent and/or CFO, the concern shall be brought to the attention of the board president who shall be empowered to contact the district’s legal counsel, Office of the Auditor of the State of Iowa, insurance agent, auditing firm, and/or any other agency to investigate the concern or complaint. Upon approval of the board, the superintendent or CFO may contact the Office of the Auditor of the State of Iowa and/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 as often as deemed necessary. The superintendent or CFO may order a complete forensic audit if such an audit would be useful and beneficial to the district.

The superintendent or CFO shall ensure the Office of the Auditor of the State of Iowa, is notified of any suspected embezzlement, theft, and/or other financial irregularity pursuant to Iowa law. In the event there is an investigation, the district shall maintain relevant records for use in the investigation. Employees found to have altered or destroyed records will be subject to disciplinary action, up to, and including termination.

Legal References:
American Competitiveness and Corporate Accountability Act of 2002, Pub. L. No. 107-204.
Iowa Code §§ 11, 279.8.

 Cross-Reference:
802.41 Use of District Property & Equipment 
804.50 Financial Audits

Adopted:
February 7, 2011

Reviewed:
November 21, 2016
February 20, 2017
December 16, 2021

Revised:
November 21, 2016
January 18, 2022