Series 3000: Business/Non-Instructional Operations

3011 Internal Controls

The Board of Education (Board) expects all Board members, employees, volunteers, consultants, vendors, contractors, students and other parties maintaining any relationship with the school district to act with integrity, due diligence, and in accordance with all laws in their duties involving the school district’s resources. The Board is entrusted with public dollars and no one connected with the school district should do anything to erode that trust. 

Internal control is the responsibility of all employees of the school district. The Superintendent and Business Manager shall be responsible for developing internal controls designed to prevent and detect fraud, financial impropriety, or fiscal irregularities within the school district subject to review and approval by the Board. Administrators shall be alert for any indication of fraud, financial impropriety, or irregularity within the administrator’s area of responsibility. 

Any employee who suspects fraud, impropriety, or irregularity shall report their suspicions immediately to his/her immediate supervisor or the Superintendent. The Superintendent shall have primary responsibility for any necessary investigations and shall coordinate investigative efforts with the Board’s legal counsel, auditing firm, and other internal or external departments and agencies, including law enforcement officials, as the Superintendent may deem appropriate. 

Employees bringing forth a legitimate concern about a potential impropriety will not be retaliated against and those who do retaliate against such an employee will be subject to disciplinary action up to, and including, discharge.

In the event the concern or complaint involves the Superintendent, the concern shall be brought to the attention of the Board Chairperson who shall be empowered to contact the Board’s legal counsel, insurance agent, auditing firm, and any other agency to investigate the concern or complaint. 

Upon approval of the Board, the Superintendent, may employ the school district’s auditing firm to conduct a complete or partial forensic/internal control audit annually or otherwise as often as deemed necessary. The Superintendent is authorized to order a complete forensic audit if, in the superintendent’s judgment, such an audit would be useful and beneficial to the school district. The Superintendent shall ensure the Commissioner of Education is notified of any suspected embezzlement or theft pursuant to Connecticut law. In the event there is an investigation, records will be maintained for use in the investigation. Individuals found to have altered or destroyed records will be subject to disciplinary action, up to, and including termination. 

Legal Reference:     American Competitiveness and Corporate Accountability Act of 2002, Pub. L.

                                No. 107-204

Policy adopted:     October 19, 2015     THOMASTON PUBLIC SCHOOLS Thomaston, Connecticut