§ 36.02 FRAUD PROGRAM AND FINANCIAL CONTROLS POLICY.
   (A)   Creating an atmosphere of honesty and high ethics. It is the responsibility of the Council to create an atmosphere of honesty and ethical conduct for the Council and the employees and volunteers of the town. A manual of recommendations of procedures has been created and is adopted as instructional assistance for this policy by this reference.
   (B)   A positive workplace environment. The town management of the Council and the Mayor must establish a positive workplace environment for all employees and volunteers in which positive and negative feedback is accepted and becomes the basis for creating a better workplace environment.
   (C)   Hiring and promoting employees and volunteers. The Council and the Mayor will establish policies for the hiring and promotion of employees and volunteers based upon the standards of honesty and ethical conduct.
   (D)   Training. All employees and volunteers shall receive proper training from the department manager and the training designees including training in the code of ethics and standards of honesty expected of all employees and volunteers. (See the attachment #1 to the manual for those standards of conduct.)
   (E)   Confirmation. The Council, Mayor, employees and volunteers of the town shall individually be held accountable for their actions within the code of conduct, especially with all management and financial functions of the town.
   (F)   Discipline. Any breach of the code of conduct by any individual in the management and workforce of the town shall be disciplined in accordance with the severity of the breach and the parameters of the law as prescribed by the Council.
   (G)   Evaluating processes and controls. It is the responsibility of the Council to periodically evaluate and review the process and controls of the town to ensure strict compliance with management of anti-fraud and financial controls of the town.
   (H)   Identifying fraud risks. The Council, with assistance of the Mayor and independent auditors, shall periodically identify fraud risks and establish procedures to effectively resolve the risks.
   (I)   Mitigating fraud risks. The Council shall determine and initiate methods and programs to change the town’s activities and programs to avoid fraud or risks.
   (J)   Implementing internal controls. Upon recommendations of the Mayor or the members of the Council, the Council shall from time to time implement appropriate internal controls to resolve all risks of fraud in financial management and in employee authority over receipts, expenses, equipment and supplies of the town.
   (K)   Developing oversight procedures. The Council is responsible for all oversight procedures and shall establish rules of procedure for oversight of all financial aspects of the town and for the proper management of all financial aspects of the town and for the proper management of all town assets, equipment and supplies. The oversight responsibility shall include final authority for oversight of all town employees and volunteers.
   (L)   Specific management issues. The Town Manager shall instruct all volunteers and employees of the town as to specific issues involving possibilities of risk and fraud as follows:
      (1)   Access to facilities and equipment:
         (a)   Distribution of keys, access codes, electronic openers;
         (b)   Authority for access;
         (c)   Responsibility for closing and locking facilities and equipment; and
         (d)   Clearance with “on-call” volunteer or employee.
      (2)   Financial controls:
         (a)   Double review of receipts, deposit and expenses;
         (b)   Monthly accounting for budget compliance;
         (c)   Reconciliation of accounts by separate review; and
         (d)   Compliance with budget.
      (3)   Equipment and supply supervision:
         (a)   Periodic physical inventory of equipment and supplies;
         (b)   Separate inventory semi-annually;
         (c)   Monthly replacement;
         (d)   Recommend actions of obsolescence; and
         (e)   Sign out personnel equipment, clothing and supplies.
      (4)   Personnel training and assignments:
         (a)   The Department Manager shall oversee all training and assignments;
         (b)   Address volunteer and employee recommendations and complaints; and
         (c)   Compliance in the scheduling and assignment programs.
      (5)   Disciplinary measures for failure to conform to management policy.
   (M)   Audit Committee or Board of Directors. The Council may appoint an Audit Committee or act as an Audit Committee as a Board to review and oversee all aspects of the policy and to recommend any changes, amendments or altercations to this policy.
   (N)   Management. The Town Manager is responsible for management and overseeing the day to day activities of the town and the conduct of all employees and volunteers within the parameters of this policy. The Council is the final responsible party for the oversight and management of this policy for the town and shall be accountable for its establishment, maintenance and enforcement.
   (O)   Independent auditors. The Council shall employ independent auditors to annually review and assess the implementation and fiscal controls required by this policy. Any recommendations for amendment shall be presented by the independent auditors to the Council for review and possible implementation by the Council.
   (P)   Code of conduct. A code of conduct for honesty and ethical conduct of all individuals involved as elected Council members, employees and volunteers of the town is attachment #14 to the manual and the same is adopted by the Council as a standard of conduct to avoid the risks of fraud in all activities and financial affairs of the town.
(Res. 08-001, passed 1-22-2008)