Section 13 Auditing
Policy 13-1 SUSPECTED FRAUDULENT ACTIVITIES, MISAPPROPRIATIONS AND SIMILAR IRREGULARITIES.
DISTRIBUTION: Mayor and Council Members
All City Employees
SUBJECT: Suspected Fraudulent Activities, Misappropriations, Improper Actions
PURPOSE: To communicate to City of Lawton employees and Council members
regarding the investigation of suspected fraudulent activities, misappropriations, improper
actions 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
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, improper
action or similar irregularity be promptly identified and investigated.
DEFINITIONS: The terms fraudulent activities, misappropriations, improper
similar irregularities include, but are not limited to, such things as:
(a) Forgery or alteration of checks, drafts, securities,
(b) Any misappropriation of funds, securities, supplies
(c) Any irregularity or improper actions in the handling
or reporting of money transactions;
(d) Disappearance of furniture, fixtures and equipment;
(e) Any similar improper action 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.
PROCEDURES: It is managements responsibility to detect improprieties. It is every
employees and Council members 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,
misappropriation, improper action or irregularity), whether believed to be intentional or
unintentional, is or was in existence in their area. As soon as an impropriety is detected or
suspected, the Internal Auditor must be contacted immediately. The Auditing Division is
responsible for the investigation or for the direction of the investigation of any suspected
irregularity and the Internal Auditor will coordinate all investigations with the City Manager,
Assistant City Manager and the City Attorney.
To report any suspected fraudulent activity, misappropriation, improper action or irregularity,
any City employee or Council member may contact the City of Lawton Auditing Division in any
of the following ways:
a. Enclose information in a sealed envelope and place
in interoffice mail.
b. Come to the Auditing Division in person or call their
office at 581-3367 or
Management will support the City of Lawtons 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 effectively recover any losses from the offender
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
3. Not discuss the case with anyone inside the organization
other than the Legal
Department or the Auditing Division
unless authorized by the City Attorney or
the Internal Auditor.
4. Direct to the Internal Auditor all inquiries from the suspected individual,
or their attorney. Proper response to such an inquiry should be, Im not at liberty to discuss
matter. Under no circumstances should there be any reference to what you did,
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 current existing
employees and Attachment B new employees)
AND RESCISSION: This policy shall be in effect from and after the 12th
day of July 2006,
and will supersede Administrative Policy 13-1 dated August 11, 1998.
DEPARTMENT: Auditing Division
July 11, 2006
Approved as to form and legality:
John H. Vincent
July 11, 2006
EMPLOYEE ACKNOWLEDGEMENT FORM
FOR RECEIPT OF LAWTON COUNCIL POLICY 13-1
SUSPECTED FRAUDULENT ACTIVITIES, MISAPPROPRIATIONS, IMPROPER ACTIONS
AND SIMILAR IRREGULARITIES
By my signature below, I acknowledge receipt of the City of Lawton Council Policy 13-1,
Suspected Fraudulent Activities, Misappropriations, Improper Actions and Similar Irregularities.
I am advised that this policy contains important information which affects the conditions of my
employment with the City of Lawton, and I realize that violation of this policy could result in the
termination of said employment. I further understand that it is my responsibility to review, know
and understand this policy and retain it for future reference.
Employee/Printed Name of Applicant
Date Copy received by Employee/Applicant
(CP 13-1, Amended, 07/11/2006, Prior Text)