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 and Similar Irregularities.

PURPOSE:    To communicate to City of Lawton employees and Council members a policy 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 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, improper action or similar irregularity be promptly identified and investigated.

DEFINITIONS:     The terms fraudulent activities, misappropriations, improper actions 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;
    (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.

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, 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
           581-3356.

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 effectively recover any 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        
            Internal Auditor.

    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, 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 “current existing employees” and Attachment B “new employees”)

REFERENCES:    None

EFFECTIVE DATE
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.  


RESPONSIBLE
DEPARTMENT:    Auditing Division

__________________________
JOHN PURCELL
MAYOR
July 11, 2006

Approved as to form and legality:

__________________________
John H. Vincent
City Attorney
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

_______________________________________
Employee/Applicant Signature

_______________________________________
Date Copy received by Employee/Applicant




















Attachment “A”


(CP 13-1, Amended, 07/11/2006, Prior Text)