CP097 (Fraud Assessment and Investigation)CITY OF JANESVILLE Policy No. 97
Page 1 of 6
CITY COUNCIL POLICY STATEMENT
Date Issued: 2/22/16
Reviewed: 10/10/22
General Subject: Administration Effective Date: 10/11/22
Special Subject: Fraud Assessment Cancellation Date
and Investigation Supersedes
Responsible Finance Office
Dept/Div:
PURPOSE
This policy is adopted to identify responsibilities, establish
procedures and controls to aid in the prevention, detection,
reporting, and investigation of possible cases of fraud
involving the City of Janesville’s operations, resources and/or
finances. This policy applies to any actual or suspected fraud
involving a City employee (including management), City
Councilmember, consultant, vendor, contractor, outside agency,
or any person conducting business with the City.
STATEMENT OF POLICY
The City of Janesville does not tolerate any type of fraud. The
City of Janesville’s policy is to promote consistent, legal, and
ethical behavior by assigning responsibility for reporting fraud
and providing guidelines to conduct investigations of suspected
fraudulent behavior.
POLICY VIOLATIONS
Failure to comply with this policy subjects an employee to
disciplinary action up to and including termination of
employment. Failure to comply by a consultant, vendor,
contractor, outside agency, or any other person conducting
business with the City can result in cancellation of the
relationship with the City. The City of Janesville will pursue
prosecution if investigation results indicate possible criminal
activity.
DEFINITIONS
For the purposes of this policy “fraud” refers to, but is not
limited to:
• Any dishonest or fraudulent act
• Misappropriation of funds, securities, supplies, or other
assets
• Impropriety in the handling or reporting of money or
financial transactions
CITY OF JANESVILLE Policy No. 97
Page 2 of 6
CITY COUNCIL POLICY STATEMENT
Date Issued: 2/22/16
Reviewed: 10/10/22
General Subject: Administration Effective Date: 10/11/22
Special Subject: Fraud Assessment Cancellation Date
and Investigation Supersedes
Responsible Finance Office
Dept/Div:
• Profiteering as a result of insider knowledge of City
activities
• Disclosing confidential and proprietary information to
outside parties
• Disclosing to other persons securities activities engaged
in or contemplated by the City
• Accepting or seeking anything of material value from
contractors, vendors, or persons providing services /
materials to the City.
• Destruction, removal, or inappropriate use of records,
furniture, fixtures, and equipment; and/or
• Any similar or related irregularity
FRAUD REPORTING
It is the responsibility of every employee to immediately report
suspected fraud or other dishonest conduct. Reporting protocol
for suspected fraud is as follows:
Within a Department:
• Department Head and City Manager
Involving a Department Head:
• City Manager and Deputy City Manager
Involving the City Manager:
• Council President and Council Vice President
Involving a City Councilmember:
• City Manager and City Attorney
Involving a Vendor/Contractor:
• Department Head and City Manager
CITY OF JANESVILLE Policy No. 97
Page 3 of 6
CITY COUNCIL POLICY STATEMENT
Date Issued: 2/22/16
Reviewed: 10/10/22
General Subject: Administration Effective Date: 10/11/22
Special Subject: Fraud Assessment Cancellation Date
and Investigation Supersedes
Responsible Finance Office
Dept/Div:
This policy includes a form that employees can use to report the
suspected fraud or dishonest activity. Those who the fraud is
reported to are to accept and acknowledge receipt of the fraud
reporting form. It is by design that a form be completed and
that two individuals are to be involved when a suspected fraud
is reported. This process is meant to give those reporting fraud
assurances that superiors are taking the report seriously and
are acting in good faith to investigate.
Any reprisal against an employee or other reporting individual
because that individual, in good faith, reported a violation is
strictly forbidden.
ADDITIONAL RESPONSIBILITIES OF SUPERVISORS/DEPARTMENT HEADS/
CITY MANAGER/ AND CITY COUNCIL
All employees have the responsibility for reporting fraud or
dishonest behavior. However, supervisors and other City
management personnel have an additional duty to undertake
deterrence and detection actions. These actions include:
1. Awareness of risk for fraudulent or dishonest acts in their
respective Departments.
2. Placement and maintenance of effective monitoring of
control procedures to prevent fraudulent or dishonest
activity.
3. Placement and maintenance of effective monitoring of
control procedures to detect fraudulent or dishonest
activity promptly if prevention efforts fail.
Authority to carry out these additional responsibilities may be
delegated. However, accountability for their effectiveness will
remain with Department Heads.
INVESTIGATIVE STANDARDS
The following shall guide all investigations into potential
fraudulent behavior/actions or dishonest behavior:
CITY OF JANESVILLE Policy No. 97
Page 4 of 6
CITY COUNCIL POLICY STATEMENT
Date Issued: 2/22/16
Reviewed: 10/10/22
General Subject: Administration Effective Date: 10/11/22
Special Subject: Fraud Assessment Cancellation Date
and Investigation Supersedes
Responsible Finance Office
Dept/Div:
1. Those investigating possible fraud must observe strict
confidentiality and should not discuss the case, facts,
suspicions or allegations with anyone unless specifically
asked to do so by the City Manager, Council President, or
law enforcement.
2. Those involved in investigating fraudulent or dishonest
behavior may assign responsibility for all or part of any
investigation to the Janesville Police Department, City
Attorney, or other person or agency that may be warranted.
3. No person shall communicate with the suspected individual
or organizations about the matter under investigation or
alert suspected individuals that an investigation is under
way.
4. All investigations are to be carried out in an impartial
and confidential manner, without regard to the suspected
individual’s length of service, position/title, or
relationship with the City.
5. Every effort will be made to protect the rights and
reputations of everyone involved, including the individual
who in good faith alleges perceived misconduct as well as
the alleged violator(s).
6. The investigator(s) will have free and unrestricted access
to municipal records. They shall have authority to examine,
copy or remove all or any portion of files, desks, physical
or electronic storage facilities without prior knowledge or
consent of any individual who might use or have custody of
such items or facilities when it is within the scope of the
investigation or related follow-up procedures.
7. All records collected as part of the investigation are to
be kept secure at all times by the investigator(s).
8. All employees shall provide the investigators all factual
and relevant details relating the alleged fraud or
dishonest behavior to the best of their knowledge, without
partiality or prejudice to any person.
9. All inquiries regarding alleged fraud or dishonest behavior
CITY OF JANESVILLE Policy No. 97
Page 5 of 6
CITY COUNCIL POLICY STATEMENT
Date Issued: 2/22/16
Reviewed: 10/10/22
General Subject: Administration Effective Date: 10/11/22
Special Subject: Fraud Assessment Cancellation Date
and Investigation Supersedes
Responsible Finance Office
Dept/Div:
and/or its follow up investigation shall be referred to the
City Manager or in cases involving the City Manager the
Council President, including but not limited to those from
an attorney, press, law enforcement and the person(s) under
investigation.
INVESTIGATIVE PROCEDURES
The City Manager has primary responsibility for coordinating the
investigation of reported fraudulent and dishonest activity and
the associated interaction with law enforcement and other
parties to the investigation. In cases involving the City
Manager, the City Council President shall have this
responsibility.
Once a report of a suspected fraudulent activity is received in
accordance with this policy, the complaint shall be documented
using the reporting form. A preliminary investigation shall be
conducted to determine the credibility of the report.
If the report appears credible, the City Manager, or in certain
cases the Council President, will prepare an incident report and
provide such report to the Common Council, City Attorney, and
City Auditor. The City Manager, and in some cases the Council
President, will prepare a report as soon as possible after the
fraud has been confirmed and shall document the content of the
investigation, findings, and any disciplinary action recommended
or taken as a result of the findings. The findings are to be
referred to the Common Council in closed session.
Each City employee or official involved in an investigation of
suspected fraud or dishonest act will keep the content of the
investigation strictly confidential to the full extent provided
by law. Investigation results will be disclosed to the accused,
the accuser, Common Council, City Attorney and District Attorney
if applicable.
CITY OF JANESVILLE Policy No. 97
Page 6 of 6
CITY COUNCIL POLICY STATEMENT
Date Issued: 2/22/16
Reviewed: 10/10/22
General Subject: Administration Effective Date: 10/11/22
Special Subject: Fraud Assessment Cancellation Date
and Investigation Supersedes
Responsible Finance Office
Dept/Div:
DISCIPLINARY ACTION
Employees who have engaged in fraudulent and dishonest activity
and those who intentionally report false or misleading
information may be subject to disciplinary action up to and
including termination and/or criminal charges.
RISK ASSESSMENT
Risk assessments shall also be reviewed upon staff turnover,
organizational restructuring, changing technology or other
environmental changes that might occur throughout a year.
CITY OF JANESVILLE FRAUD/DISHONEST BEHAVIOR REPORT FORM
Today’s Date: ____________________
Name of Employee/Individual Making Report
of Fraud and/or Dishonest Behavior: ______________________________
Date/Time of the Alleged Fraud and/or
dishonest behavior: ______________________________
Describe Event(s): Note: if you prefer to describe what you saw instead of writing a statement then you may request
that your statement be taped. You may also attach a written statement.
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
Other Information you would like to provide:
__________________________________________________________________________________________________
__________________________________________________________________________________________________
___________________________________________________________
I, _____________, acknowledge that I have read the City of Janesville “Fraud Assessment and Investigation Policy.” I
understand that I have the responsibility of keeping the information I just reported confidential during the investigative
process. I am providing this information in good faith. I realize that if the information I am giving is false or is misleading,
is meant as retribution or other motivation in order to hurt the reputation or character of the individual(s) I am reporting
on, that I understand that I am subject to discipline up to and including termination of employment.
__________________________________
Reporting Individual Signature and Date
This report was received, receipt acknowledged, by the following individuals:
______________________________ __________________________ _________________________
Print Name Date Print Name Date Print Name Date
______________________________ __________________________ __________________________
Signature Signature Signature
______________________________ __________________________ __________________________
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