The Village is committed to protecting its revenue, property, proprietary information, and other assets. The Village will not tolerate any misuses or misappropriations of those assets. The Fraud Prevention Policy is established to provide guidance to employees when misuses or misappropriation of Village assets is suspected and to facilitate the development of protocols and practices which will aid in the detection and prevention of fraud.
The policy applies to any fraud perpetrated by employee, officials, as well as consultants, vendors, contractors, outside agencies and/or any other parties with a business relationship with the Village. Any investigation commenced pursuant to this policy shall be undertaken without regard to a person's length of service, position, or title, or relationship to the Village.
The term fraud includes, but is not limited to, the following:
• Any dishonest or fraudulent act.
• Forgery or alteration of any document or account belonging to the Village.
• Forgery or alteration of a check, bank draft, or any other financial document.
• Unauthorized disclosure of confidential and proprietary information.
• Unauthorized disclosure of securities activities of the Village.
• Misappropriation of funds, securities, supplies and other assets.
• Accepting or seeking anything of substantial value from contractors, vendors or persons providing services/materials to the Village.
• Authorizing or receiving payment for goods not received or services not performed.
• Impropriety in the handling or reporting of money or financial transactions.
• Intentional violation of the Village's purchasing policy.
• Profiteering because of inside knowledge of Village activities.
• Theft, destruction, removal or fraudulent use of Village records and intellectual property.
• Actions related to concealing or perpetuating abovementioned activities.
If there are any questions as to whether an act constitutes fraud, please contact Human Resources.
All employees of the Village, regardless of position have a responsibility in regards to Village funds and other assets. Village employees are responsible for safeguarding village resources and ensuring that those resources are used only for authorized purposes in accordance with Village policies and applicable state and federal laws.
• When fraud is suspected, observed, or otherwise made known to an employee, the employee must immediately report the activity to his/her supervisor.
• If the employee has reason to believe his/her supervisor may be involved in fraudulent activity, the employee is obligated to report the activity to the next higher level of management or to Human Resources or the Village Manager.
• The reporting employee shall refrain from discussing the matter with any other person within the Village unless directed to do so by Human Resources Manager.
• All employees shall cooperate fully with any investigation performed by the Village, oversight agencies and/or law enforcement officials.
Any Village employee reporting suspected, observed, or otherwise known fraudulent activity will be held harmless and not subject to retaliation.
All management personnel are responsible for detecting and preventing fraudulent activities in their respective work areas. All management personnel will be familiar with the types of activities that constitutes fraud and be alert for any indication that improper or dishonest activity is or was in existence in his/her department.
• If a supervisor suspects fraud or has received a report of fraud from an employee, he/she must contact the department Manager immediately.
• When a Department Manager is informed by a supervisor that fraud is suspected, the Department Manager must immediately contact Human Resources Manager who will consult with the Village Manager and legal counsel.
• Upon investigation, if the Village determines that fraud exists, the Village shall take immediate action to halt the fraudulent activity. If criminal activity has occurred, the Village shall report the activity to the appropriate agencies and/or law enforcement officials.
• All management personnel shall cooperate fully with any investigation performed by the Village, appropriate agencies and/or law enforcement officials.
• Following all incidents of fraud, or at least on an annual basis, management personnel shall conduct a review of internal controls, policies and procedures for the prevention and detection of fraud and implement new and/or modify controls when necessary.
All employees in a fraud investigation shall treat all information received confidentially. A person reporting suspected fraud may remain anonymous except as otherwise required by law.
Investigation results will not be disclosed or discussed with anyone other than those who have a legitimate need to know. Any employee contacted by the media with respect to a fraud investigation shall refer the media person the Village Manager.
Employees who have committed fraud will be subject to disciplinary action up to and including termination. Any disciplinary action taken by the Village because of its investigation shall be in accordance with terms and conditions of applicable collective bargaining agreements and the employee handbook. In all cases, the Village reserves the right to refer the matter to appropriate agencies and/or law enforcement officials for independent review, investigation and/or prosecution. The Village's internal investigation and disciplinary process shall be conducted independently from any external review performed.
Human Resources is responsible for the administration, revision, interpretation, and application of this policy. The policy will be reviewed annually and revised as needed.
In addition to this policy, the Village shall comply with all applicable state and federal laws addressing fraud prevention.
(Ord. 23-1853, passed 5-3-23)