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Theft and Fraud Prevention Policy

OBJECTIVES

  1. To prevent and detect theft and fraudulent actions by persons who are employed or contracted by the School or who are service recipients of the school.
  2. To conduct any investigation into any theft or fraudulent actions in a manner that conforms to the principles of natural justice and is procedurally just and fair.
  3. To establish systems and procedures to guard against the actions of theft and fraud. The Principal is to report such actions to the Board Chairperson as prescribed in the guidelines set out below.

GUIDELINES

  1. As preventative measures against theft and fraud, the Principal is to ensure that the school’s physical resources are kept secure and accounted for, including ensuring that:
    • The school’s financial systems are designed to prevent and detect the occurrence of fraud. All such systems must meet the requirements and standards as set out in the Public Finance Act 1989, Section 45C(b) and of generally accepted accounting practice promulgated and supported by the Institute of Chartered Accountants of New Zealand.
    • Staff members who are formally delegated responsibility for the custody of physical and financial resources by the Principal are proven competent to carry out such responsibilities and that such persons are held accountable for the proper execution of their responsibilities.
    • All staff members are aware of their responsibility to immediately inform the Principal should they suspect or become aware of any improper or fraudulent actions by staff, suppliers, contractors, students or other persons associated with the school.
  2. In the event of an allegation of theft or fraud the Principal (or acting Principal in the absence of the Principal) shall act in accordance with the following procedures:
    • Immediately refer the matter to the New Zealand Police or proceed as outlined in this paragraph.
    • So far as it is possible and within 24 hours the Principal is to:
      • Consult with the person(s) who provided the information and request a written statement from them. The statement is to include details as to the nature of the theft or fraud, the time and circumstances in which it occurred, the quantity and/or value of the theft or fraud and the person(s) allegedly involved;
      • In cases where the person(s) is/are unwilling to provide a written statement, record the details of the allegation, as per 2b (i), above;
      • Decide on the initial actions to be taken, including consulting with senior members of staff;
      • Inform and consult with the Board Chairperson regarding the information received.
    • In conjunction with the Board Chairperson, the Principal shall decide whether or not a prima facie case of theft or fraud exists.
    • Where a prima facie case is deemed not to exist, then the Principal is to document this decision and record that no further action is to be taken.
    • Where a prima facie case is deemed to exist, then the Principal shall:
      • In writing, inform the person who is the subject of the allegation of theft or fraud concerning the allegation that has been received;
      • Meet with the person (and his or her representatives, if desired) to discuss the allegation;
      • Obtain a written response from the person. (If the person wishes to supply only a verbal response, then the written response is deemed to be the minutes of the meeting described in 2e(iii), with the accuracy of the minutes attested by all persons present.);
      • Advise the person in writing of the processes that will be followed thereafter.
    • Further, the Principal may, as appropriate:
      • Investigate the matter further and, if necessary, commission an independent expert investigation and/or seek legal advice;
      • In the case of fraud, require a search for written evidence of the possible fraudulent action to determine the likelihood or not of such evidence;
      • Inform the Manager, National Operations, Ministry of Education local office and/or the school’s auditors.
    • Once all available evidence is obtained, the Principal shall consult the Board Chairperson. The Board Chairperson may, if necessary, seek legal or other advice as to what further action should be taken. Possible actions include, but are not restricted to:
      • Taking no action;
      • Invoking appropriate disciplinary procedures contained in any applicable contract of employment should the person be a staff member;
      • Referring the matter and copies of all documentation to the New Zealand Police.
  3. The procedures outlined in Guideline 2 are to be followed mutatis mutandis where there is more than one person involved in any allegation.
  4. The Board recognises that supposed or actual instances of theft or fraud can affect the rights and reputation of the person or persons implicated. Therefore, the following principles shall apply:
    • All matters related to the case shall remain strictly confidential;
    • All written information is to be kept secure;
    • Should any staff member disclose information related to an alleged or proved case, the Principal shall decide whether a breach of confidence has occurred and whether further action is required. Any such action must align with the pertinent conditions contained in any applicable contract of employment and any code of ethics or code of responsibility by which the staff member is bound.
  5. The Board affirms that the response to any allegation of theft or fraud must be subject to due process, equity and fairness.
  6. Any intimation or written statement made on behalf of the School and related to any instance of supposed or actual theft or fraud shall be made by the Board Chairperson who shall do so after consultation with the Principal and if considered appropriate after taking expert advice.

Allegations Concerning the Principal or a Trustee

  1. Any allegation concerning the Principal or member of the Board of Trustees should be made to the Board Chairperson. The Chairperson will then advise the manager of the local office of the Ministry of Education and investigate in accordance with the requirements of this Policy.
  2. Any allegation concerning the Chairperson of the Board of Trustees should be made to the Principal. The Principal will then advise the manager of the local office of the Ministry of Education and investigate in accordance with the requirements of this Policy.

Approval

  1. Before each subsequent approval of this policy, the Principal is to circulate it to all staff and include a copy in the Cobham Intermediate School Policy Manual, copies of which shall be available to all staff. The Principal shall arrange for all new staff to be made familiar with this Policy.
  2. No variations of this policy or amendments can be made except by the unanimous approval of the Board.

View Policy in Adobe Acrobat PDF format

Chairperson: John Talbot

Approval Date: 16 June 2008

Review Date: May 2009

 

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