The Town hereby establishes this additional Materiality Policy under I.C. 5-11-1-10, I.C. 5-11-1-21 and I.C. 5-11-1-27.
(A) Materiality defined. MATERIALITY in the Town is hereby defined as five thousand dollars ($5,000) per occurrence. That is, if one occurrence of a loss or shortage or other irregularity is equal or greater than five thousand dollars ($5,000), it must be reported to the SBOA. This MATERIALITY definition is not limited to defalcations or suspicious activity involving only cash transactions. If supplies, equipment or other fixed assets belonging to the Town are suspected of being misappropriated or stolen or used in a manner not authorized by Town Officials and the value of those supplies, equipment or fixed assets are approximately five thousand dollars ($5,000) or more, that misuse or series of misuse should be reported. That is not to say that if a loss or shortage is less than five thousand dollars ($5,000) it should be ignored. If there is an event or series of events, within the same office of department that appears to be a structuring event to defraud or misappropriate Town funds or property, that event or series of events should be reported to the SBOA. Occurrences falling under the MATERIALITY threshold shall be investigated and resolved by the Clerk-Treasurer and other Town officials as necessary.
(B) Material variances, losses, shortages and thefts. All erroneous or irregular material variances, losses, shortages, or thefts of political subdivision funds or property shall be reported immediately to the SBOA. For all material variances, losses, shortages or thefts, the SBOA shall:
(1) Determine the amount of funds involved and report the amount to the appropriate government and law enforcement officials;
(2) Determine the internal control weakness that contributed to or caused the condition; and
(3) Make written recommendations to the appropriate legislative body or appropriate official overseeing the internal control system addressing:
(a) The method of correcting the condition; and
(b) The necessary internal control policies and internal control procedures that must be modified to prevent a recurrence of the condition.
(C) Notification of fiscal misconduct. If any Town employee knows or has a concern that other Town employees are engaged in fiscal misconduct, it is his/her duty to immediately notify their Supervisor or at least two (2) members of the Town Council, or if the Supervisor or a Town Council member is involved, then notification should be made to the Town Attorney. Following the procedure outlined in I.C. 5-11-1-9.5(a)(2), the notification by the individual should be in the form of sworn statement (in writing) that the individual believes the allegation to be true. Per state law, the Town may not retaliate against an employee of the Town for making a sworn statement on the subject of this fiscal misconduct.
(D) Immediate reporting by public official. All public officials who have actual knowledge of, or reasonable cause to believe, that there has been a misappropriation of public funds, in any dollar amount, must immediately send written notice of the misappropriation to the State Board of Accounts and the local prosecuting attorney pursuant to I.C. 5-11-1-27(I).
(Ord. 2016-40, passed 12-15-16)