This policy applies to any irregularity involving employees, consultants, vendors, contractors or any
other parties who have a business relationship with the district.
Definitions
Corruption – Corruption arises when a person receives any benefit that influences him/her and cause
him/her to act differently when conducting district business.
Debt – Any outstanding balance owed the district as well as any outstanding balance owed to a
district-sponsored organization or club operating within the policies of the district is considered debt.
Debt shall include, but not be limited to, payment for books, school supplies, school equipment or
other school property lost or damaged beyond ordinary wear and tear, food service accounts and
fundraiser collections.
Fraud – For the purpose of this policy, fraud (or fraudulent act or activity) is the intentional, false
representation or concealment of a material fact for the purpose of inducing another to act upon it
to his or her injury. Fraudulent activity includes misappropriation and other fiscal irregularities,
examples of which include, but are not limited to:
1. Any dishonest or fraudulent act.
2. Misappropriation of funds, supplies or other assets.
3. Impropriety in the handling or reporting of money or financial transactions.
4. Profiteering as a result of insider knowledge of district activities.
5. Violation of applicable conflict of interest policies.
6. Accepting or seeking anything of material value from contractors, vendors or persons
providing services or materials to the district except as allowed in the applicable conflict of
interest policy.
7. Destruction, removal or inappropriate use of records, furniture, fixtures or equipment.
8. Any similar or related irregularity.
Fraud Prevention
The district is committed to protecting the public funds with which it has been entrusted.
Minimizing the losses to fraud and corruption is an essential part of ensuring that all of the district’s
resources are used for the purpose for which they are intended.
The public is entitled to expect the district to conduct its affairs with integrity, honesty and openness,
and demand the highest standard of conduct from those working for it and with it.
Every effort shall be made to protect the financial resources of the district by collecting all debts
owed the district.
Reporting Process
If fraud or corruption is suspected, the matter should be reported without delay. Employees should
report suspicions to a supervisor at the outset and retain all evidence. However, if it is thought the
supervisor might be involved or there may be a conflict of interest, the matter should be reported
directly to a more senior administrator.
The district recognizes that some individuals may be reluctant to report suspicious activity for fear
of reprisal. To ease this reluctance, the district will investigate all reported incidences in a
confidential manner. In addition, the district:
1. Prohibits retaliation against anyone reporting in good faith.
2. Will take disciplinary action, including termination, against those who retaliate.
3. Will not attempt to destroy or conceal evidence of a poor or unacceptable practice or
misconduct and will take disciplinary action against anyone who does.
4. Will not include confidentiality clauses in contracts that restrict, forbid or penalize reporting.
Students who, in good faith, report suspected fraud or financial misconduct will not be disciplined
or penalized for making such a report. Staff members who receive such a report are obligated to
notify the superintendent or designee.
Investigation Process
The purpose of any investigation is to establish the facts in an equitable and objective manner.
The process will involve the use of authority or delegated powers to:
1. Screen allegations or information to gauge their credibility;
2. Secure all evidence;
3. Interview suspects;
4. Interview witnesses;
5. Take statements;
6. Complete a report of findings for submission to the Board and any personnel deemed
appropriate by the superintendent/designee, with a recommendation as to whether
disciplinary action is appropriate; and
7. Coordinate, when necessary, with departments or other agencies (including the police).
The superintendent/designee will establish and record the basis of the concerns raised and establish
what further actions are required. If the superintendent is the subject of the investigation, the Board
president will designate an appropriate person to conduct the investigation.
The Board will be informed of all reported disclosures and the actions being taken. In the case of
disclosures on alleged fraud and corruption, the Chief Financial Officer will inform the district’s
external auditors. After consultation with the superintendent and legal counsel, the Board will
decide whether to prosecute or refer the investigation results to appropriate law enforcement.
Whenever possible, the individual raising the concern will be advised of the outcome of the
investigation. If an individual is not satisfied with the response received and any subsequent action
taken, he/she should put his/her concerns in writing to the superintendent, who will arrange any
further investigation as he/she deems appropriate. The superintendent will send a written response
to the individual concerned.
Collection of Student Debt
Unless payment arrangements have been made with the district, students will be ineligible to
participate in school activities if they have an outstanding balance owed the district. While every
attempt will be made at the building level to collect the debt, any uncollected debt of students when
they leave the district due to out-of-district transfer or graduation will be sent to the district’s
designated collection agency for recovery.
* * * * * * *
Note: The reader is encouraged to check the index located at the beginning of this section
for other pertinent policies and to review administrative procedures and/or forms for
related information.
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Adopted: 05/20/2008
Revised: 02/17/2009; 09/18/2012
Cross Refs: BBF, School Board Member Ethics
BBFA, Board Member Conflict of Interest and Financial Disclosure
BCE, Board Committees/Advisory Committees to the Board
EFB, Food Services Management
GBCA, Staff Conflict of Interest
IGD, District-Sponsored Extracurricular Activities and Groups
IGDF, Student Fundraising
Farmington R-7 School District, Farmington, Missouri
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