§ 37.36 CONTROL ENVIRONMENT.
   (A)   (1) The oversight body and management demonstrate a commitment to integrity and ethical values.
      (2)   The town has the responsibility to establish and maintain an adequate system of internal control and to furnish to the Town Council, various boards and commissions, governmental agencies, creditors and others reliable financial information on a timely basis. An adequate system of internal control is necessary for the town to discharge these responsibilities.
      (3)   Controls help ensure that assets are not exposed to unauthorized access and use, transactions are properly recorded in the financial records, and the resultant financial information is reliable. External organizations and stakeholders of the town rely on financial information to make decisions toward appropriations, loans and other debt, grants, and other contractual relationships. Town resources are dependent upon the system of internal control. Auditors are required annually to report upon the adequacy of the town’s systems for control over financial reporting and compliance per I.C. 5-11-1-27(e). The safeguarding of town assets and the reliability which the town and others can place upon its financial records is dependent upon the effectiveness of the internal control process.
      (4)   The system of internal control is meant to keep the town on course toward its mission to provide effective and efficient operations, reliable financial reporting, minimize risks of asset loss, and comply with applicable laws and regulations.
      (5)   Internal control is a process. The control environment is the foundation upon which all components of internal control are based. Internal control can provide reasonable assurance, but no system of control can provide absolute assurance to the Town Council and other users of financial information.
      (6)   The Clerk-Treasurer shall be charged with:
         (a)   Evaluating the town’s internal control system for weaknesses on a periodic (but no less frequently than annual) basis, providing solutions to any discovered weaknesses, and inform employees of necessary changes in procedures;
         (b)   Establish a confidential reporting system for individuals to report suspected fraud and abuse of internal control policies; and
         (c)   Institute procedures to address violations of policies and consequences for violations.
   (B)   The oversight body oversees the entity’s internal control system. As the town’s Fiscal Officer, the Clerk-Treasurer will be the Town Council’s chief agent in implementing and managing the internal control policies and procedures.
   (C)   Management establishes an organizational structure, assigns responsibility, and delegates authority to achieve the entity’s objectives. Individuals with delegated approval authority, (e.g. elected officials and department heads) are responsible for establishing, maintaining, and supporting a system of internal controls within his, her, or their areas of responsibility and for creating the control environment that encourages compliance with town policies and procedures. All levels of management and supervision are responsible for strengthening internal controls when weaknesses are detected. Department managers should periodically review departmental procedures to ensure that the general principles of internal control are being followed.
      (3)   The Clerk-Treasurer has the primary responsibility for internal control over financial reporting and compliance with applicable laws, rules, and regulations. The Clerk-Treasurer is the town’s chief source for information and assistance to staff and department heads and will make resources available to assist in administering this policy.
      (4)   The Human Resources Department/Clerk-Treasurer is responsible for internal controls over employee recruitment, hiring, separation, promotion job classification, employee rights, and salary administration. The Human Resources Department/Clerk-Treasurer and Town Attorney are the town’s sources for information and assistance and will make resources available to assist in administering this policy.
   (D)   (1)   Management demonstrates a commitment to recruit, develop, and retain competent individuals.
      (2)   The Town Employee Handbook provides a roadmap for recruiting and maintaining quality employees. Prior to employment individuals may be subject to pre-employment screening and/or a credit history check. The town will continue to assess the best recruitment pools necessary to adequately implement and maintain quality internal controls. Job descriptions will be updated where necessary to reflect internal control responsibilities and duties. Employees will be trained in internal control methods and all training will be documented in employees’ personnel files.
   (E)   Management evaluates performance and holds individuals accountable for his, her, or their internal control responsibilities. Individuals are held accountable for his, her, or their internal control responsibilities through a recognized structure this includes relevant job descriptions, operating procedures, periodic reviews, and corrective action procedures.
(Ord. 2016-07, passed 12-19-2016)