Fraud Policy passed on 1/19/2006

St. Charles City-County Library Foundation

Fraud Policy

Fraud is defined as a deception deliberately practiced in order to secure unfair or unlawful gain.

This policy applies to any fraud, or suspected fraud, involving employees as well as Officers, Directors, Trustees, consultants, vendors, contractors, outside agencies doing business with employees of such agencies, and/or any other parties with a business relationship with the Saint Charles City-County Library Foundation, or Saint Charles City-County Library District.

Any investigative activity required will be conducted without regard to the suspected wrongdoer’s length of service, position/title, or relationship to the Foundation or the District.

The Foundation Board and Registered Agent are responsible for the detection and prevention of fraud, misappropriations, and other inappropriate conduct. Each member of the management team will be familiar with the types of improprieties that might occur within his or her area of responsibility, and be alert for any indication of irregularity.  Any fraud that is detected or suspected must be reported immediately Planning & Development Coordinator (if that person is suspected of fraud, the report should go to the President of the Foundation Board and Director of the St. Charles City-County Library District). The party to whom suspicion of fraud is reported will coordinate all investigations with the District’s Director and legal counsel and other staff who have necessity to know in order to address the issue. 

ACTIONS CONSTITUTING FRAUD:

The terms defalcation, misappropriation, and other fiscal wrongdoings refer to, but are not limited to:

·         Any dishonest or fraudulent act.

·         Forgery or alteration of any document or account belonging to the District

·         Forgery or alteration of a check, bank draft, or any other financial document.

·         Misappropriation of funds, securities, supplies or other assets.

·         Impropriety in the handling or reporting of money or financial transactions

·         Profiteering as a result of insider knowledge of District activities.

·         Disclosing information protected under the Missouri Sunshine Law. (Policy A096) 

·         Violations of existing Foundation or District ethical and fraud policies, including but not limited to: A056, E056, E056.7, E064, G074.

·         False accusations of fraudulent behavior. 

·         Destruction, removal or inappropriate use of  computer hardware, software,  records, furniture, fixtures, and equipment; and/or

·         Any similar or related inappropriate conduct

CONFIDENTIALITY:

All information will be received confidentially. Any officer, board member, or employee, who suspects dishonest or fraudulent activity will notify the Planning & Development Coordinator immediately, and should not attempt to personally conduct investigations or interviews/interrogations related to any suspected fraudulent act.

To avoid damaging the reputations of persons suspected but subsequently found innocent of wrongful conduct and to protect the Foundation and / or the District from potential civil liability, investigation results will not be disclosed or discussed with anyone other than those who have a legitimate need to know within the constraints of the Missouri Sunshine Laws.