§ 32.60  POLICY.
   (A)   Established.  The Town Council hereby establishes a policy for the town regarding erroneous or irregular variances, losses, shortages, and thefts, consistent with current applicable law.
      (1)   Purpose.  This policy is intended to comply with the provisions of I.C. 5-11-1-27, and State Examiner Directive 2015-6 issued November 18, 2015, each as currently in effect, or as amended hereafter from time to time.
      (2)   Materiality threshold.
         (a)   The materiality threshold for the town shall be $100. If the erroneous or irregular variance, loss, shortage or theft is not cash or a cash-equivalent, the value of the item at the time of the variance, loss, shortage or theft shall be used to determine whether the materiality threshold has been met.
         (b)   All erroneous or irregular variances, losses, shortages, or thefts of $100 or more, shall be reported immediately to the State of Indiana Board of Accounts. In addition, all erroneous or irregular variances, losses, shortages, or thefts which occur more than four times in a month and which in the aggregate total the amount of $200 or more, shall be reported immediately to the State of Indiana Board of Accounts.
      (3)   Knowledge of misappropriation.  A public officer who has knowledge of or reasonable cause to believe that there has been a misappropriation of public funds or assets of the public office shall immediately send written notice of the misappropriation to the State of Indiana Board of Accounts and the Office of the Lake County Prosecuting Attorney.
      (4)   Maintenance of documentation.  The town shall maintain records and documentation concerning erroneous or irregular variances, losses, shortages, or thefts in accordance with generally accepted accounting principles and the required internal control standards established as required by the State of Indiana Board of Accounts.
      (5)   Resolution of incidents not meeting the materiality threshold.  The town shall immediately, upon discovery, investigate all erroneous or irregular variances, losses, shortages or thefts, regardless of whether such meet the materiality threshold established by this town policy. Upon conclusion of each such investigation, the town shall:
         (a)   Implement procedures designed to prevent the recurrence of such incidents; and
         (b)   Take appropriate disciplinary action against the employee(s)/town official(s) responsible for the incident.
   (B)   Distribution/communication of policy.
      (1)   The Town Administrator and Clerk-Treasurer are hereby directed to copy the within established policy to all town employees, with said employees to acknowledge receipt of same by signature execution thereof.
      (2)   The Town Clerk-Treasurer is hereby authorized to communicate the within established town policy to the State of Indiana Board of Accounts, State Examiner, or any and all other jurisdictional bodies and authorities to whom such notice of adoption should be provided, including the State of Indiana Board of Accounts, among others.
(Ord. 257, passed 2-23-2016)