Prior to the adoption of CP 13-1 on 07/11/2006, Policy 13-1 read as follows.

Policy 13-1 SUSPECTED FRAUDULENT ACTIVITIES, MISAPPROPRIATIONS AND SIMILAR IRREGULARITIES.

DISTRIBUTION: Mayor and Council Members

All City Employees

SUBJECT: Suspected Fraudulent Activities, Misappropriations and Similar Irregularities.

PURPOSE: To communicate to City of Lawton employees and Council members a policy regarding the investigation of suspected fraudulent activities, misappropriations and similar irregularities. The policy also provides specific instructions for all City employees and Council members regarding appropriate action in case of suspected improprieties.

BACKGROUND: This policy applies to all City of Lawton employees and Council members. It is intended that all employees and Council members be aware of this procedure since good business practice dictates that every suspected fraudulent activity, misappropriation or irregularity be promptly identified and investigated.

DEFINITIONS: The terms fraudulent activities, misappropriations and similar irregularities include, but are not limited to, such things as:

(a) Forgery or alteration of checks, drafts, securities, etc.;

(b) Any misappropriation of funds, securities, supplies or equipment;

(d) Disappearance of furniture, fixtures and equipment;

(e) Any similar or related irregularity.

Included in the above definition is any irregularity or suspicion of an irregularity involving vendors or agencies who conduct business with the City of Lawton, City of Lawton personnel, or City of Lawton property.

POLICY/

PROCEDURES: It is management’s responsibility to detect improprieties. It is every employee’s and Council member’s responsibility to report suspected improprieties. Each Director and Supervisor should be familiar with the types of improprieties which might occur in their area and should be alert for any indication that such an impropriety (fraudulent activity, is appropriation or irregularity) is or was in existence in their area. As soon as an impropriety is detected or suspected, the Director of Internal Audit must be contacted immediately. The Internal Audit Department is responsible for the investigation or for the direction of the investigation of any suspected irregularity and the Director of Internal Audit will coordinate all investigations with the City Manager and the City Attorney.

To report any suspected fraudulent activity, misappropriation or similar irregularity, any City employee or Council member may contact the City of Lawton Auditing Department in any of the following ways:

a. Mail information to: City of Lawton

Internal Audit Department

P.O. Box 682

Lawton, OK 73502

b. Enclose information in a sealed envelope and place in interoffice mail.

c. Come to the Internal Audit Department in person or call their office at 581-3335.

Management will support the City of Lawton’s responsibilities and will cooperate with law enforcement in the detection, investigation and reporting of criminal acts, including prosecution of offenders. Every effort should be made to effect recovery of losses from the offender or from our bonding company.

Great care must be taken in the investigation of suspected improprieties or irregularities so as to avoid incorrect accusations or alerting suspected individuals that an investigation is under way and also to avoid making any statements which could provide a basis for a suit for false accusation or other offenses.

Accordingly, Council members, Directors, Supervisors and employees shall:

1. Not contact the suspected individual to determine facts or demand restitution.

2. Not discuss the case, facts, suspicions or allegations with anyone outside the City of Lawton organization, unless specifically directed to do so by the City Attorney or the Director of Internal Audit .

3. Not discuss the case with anyone inside the organization other than the Legal Department or the Internal Audit Department unless authorized by the City Attorney or the Director of Internal Audit.

4. Direct to the Director of Internal Audit all inquiries from the suspected individual, their representative or their attorney. Proper response to such an inquiry should be, “I’m not at liberty to discuss this matter.” Under no circumstances should there be any reference to “what you did,” “the crime,” “the fraud,” “the forgery,” “the misappropriation,” etc.

All City of Lawton employees will receive a copy of this policy and must acknowledge by their signature that they have read and understand this policy. (See Attachment A)

REFERENCES: None

EFFECTIVE DATE

AND RESCISSION: This policy shall be in effect from and after the 11th day of August 1998, and will supersede Administrative Policy 2-3 dated February 1, 1994.

RESPONSIBLE

DEPARTMENT: Internal Audit

__________________________

CECIL E. POWELL

MAYOR

August 11, 1998

Approved as to form and legality:

__________________________

John H. Vincent

City Attorney

August 3, 1998