Policy 7225 - Financial Fraud and Theft Prevention

Disclaimer:
RISE Charter School Financial Fraud or Theft is a criminal matter and covered by State laws. This policy is merely a guideline so that all RISE Charter School employees understand the possible repercussions of such actions. If you have questions regarding fraud and/or theft, please contact your RISE Charter School legal counsel and/or your local law enforcement agency.

Financial Fraud and Theft Prevention
All RISE Charter School employees, Board Members, consultants, vendors, contractors, and other parties maintaining a business relationship with the RISE Charter School shall act with integrity and due diligence in matters involving RISE Charter School fiscal resources. The Executive Director or designee shall be responsible for developing internal controls designed to prevent and detect fraud, financial impropriety, and fiscal irregularities within the RISE Charter School. Every member of the RISE Charter School’s administrative team shall be alert for any indication of fraud, financial impropriety, or irregularity within his or her areas of responsibility.

The Executive Director or designee shall investigate reports of fraudulent activity in a manner that protects the confidentiality of the parties and the facts. All employees involved in the investigation shall be advised to keep information about the investigation confidential. While investigating and responding to the financial fraud allegations, the Executive Director or designee or Chair of the Board will give priority to avoiding possible retaliation or reprisals.

Staff Responsibilities
Any employee who suspects that financial fraud, impropriety, or irregularity has occurred shall immediately report those suspicions to their immediate supervisor and/or the Executive Director or designee who shall have the primary responsibility for initiating necessary investigations. Additionally, the Executive Director or designee shall coordinate investigative efforts with the RISE Charter School’s legal counsel, auditing firm, and other internal or external departments and agencies, including the county prosecutor’s office and law enforcement officials, as the Executive Director or designee may deem appropriate.

An employee who believes they have suffered reprisal, retaliation, or discrimination for a report under this policy shall report the incident(s) to the Executive Director or designee. The Board will attempt to ensure that no employee who makes such a report will suffer any form of reprisal, retaliation, or discrimination for making the report. Employees are prohibited from preventing or interfering with those who make good faith disclosures of misconduct. This policy shall not apply when an employee knowingly makes a false report. In the event the concern or complaint involves the Executive Director, the concern shall be brought to the attention of the Chair of the Board who is hereby empowered to contact the RISE Charter School’s legal counsel, auditing firm, and any other agency to investigate the concern or complaint.

Definition
As used in this policy, “fraud” refers to intentionally misrepresenting, concealing, or misusing information in an attempt to commit fiscal wrongdoing. Fraudulent actions include, but are not limited to:
1. Behaving in a dishonest or false manner in relation to RISE Charter School assets, including theft of funds, securities, supplies, or other RISE Charter School properties;
2. Forging or altering financial documents or accounts illegally or without proper authorization;
3. Improper handling or reporting of financial transactions;
4. Personally profiting as a result of insider knowledge;
5. Disregarding confidentiality safeguards concerning financial information;
6. Violating Board conflict of interest policies; and
7. Mishandling (destroying, removing, or misusing) financial records of RISE Charter School assets.

Internal Controls
The following internal controls shall be a regular practice of the RISE Charter School in an effort to prevent the possibility of fraud:
1. Budgetary Transfers: The transfer of appropriations is important for the Executive Director or designee, purchasing agent, business official, and treasurer, and all should have written confirmation of the information. The purchasing agent shall be apprised if the transfer has been approved, the treasurer shall document it and the business official shall record it;
2. Treasurer’s Receipts: The treasurer should have receipts and numbered duplicates for everything paid out in his or her custody;
3. Checks: The treasurer shall keep personal custody of any signature stamps and maintain a log for every check written;
4. Audit: An individual not connected to the business office should audit the check register regularly;
5. Conduct Background Checks on Potential Business Office Employees: Check all possible references, not just those offered, and perform criminal background checks on key business officials and other warranted positions; and
6. Segregate functions within the business office so as to avoid the opportunity for fraud without collusion.

 

 

Policy History:
Adopted on: December 13, 2021
Revised on:
Reviewed on: