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I. PURPOSE

The purpose of this policy is to define employee and management responsibilityfor reporting fraud or potential fraud and to establish procedures for addressingwrongful conduct.

II. POLICY

All employees of Linn County have the responsibility to ensure that Countyfunds and resources are used only in activities that support the mission of theCounty; to protect County funds and resources from theft, misuse,misappropriation and other conduct that may be injurious to the financial welfareand reputation of the County; and, to ensure the integrity of the County’sfinancial records through accurate reporting.

III. SCOPE

This policy is applicable to all Linn County departments and employees orrelatives, friends, or associates from or through activities and transactionsrelated to the business of Linn County.

IV. DEFINITIONS AND EXAMPLES

Financial misconduct refers to any intentional misuse or conversion of Countyproperty or resources to acquire financial gain. Financial misconduct typicallyinvolves theft, forgery, or embezzlement. Examples of financial misconductinclude but are not limited to:

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Falsification of records related to financial transactions funded by externalagencies (such as Medicaid)

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Falsification or alteration of various records related to accounting andfinancial reporting

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Falsification or alteration of records related to employee tax reporting andemployee benefit plans

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Alteration of records including financial reports, attendance andtimekeeping reports

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Submission of fraudulent business expenses for reimbursement

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Acceptance or offering of bribes, kickbacks, or rebates

Distribution: Auditor’s Office, EmployeeHandbook, Intranet

BOARD OF SUPERVISORS

County of Linn, Iowa

Revision No.:Reference:Board of Supervisors Minutes of 03/26/07 and03/28/07Directive Number:Approval Date:03/28/07Effective Date:03/28/07Policy Section & Number:

FM - 001

SUBJECT:

Reporting and Investigation of Fraudor Financial Misconduct

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Theft, destruction, or misappropriation of funds, securities, supplies,inventory or any other asset

V. COMPLIANCE OFFICE

The Compliance Office is responsible for investigating and resolving allreported complaints and allegations concerning fraud or financial misconduct.Compliance Officer – The Finance Director is designated as the ComplianceOfficer. In the event the Finance Director is unavailable, the Budget Directorassumes those responsibilities. The Compliance Office telephone number is892-5010.

VI. PROCEDURESReporting Potential Financial Misconduct

When financial misconduct is suspected or uncovered, it should be reportedpromptly and in a confidential manner to the Compliance Officer.To report known or suspected financial misconduct, contact the ComplianceOfficer. If the potential misconduct is that of the Compliance Officer, initialcontact should be with the County Attorney and not the Compliance Officer.Elected officials or department heads who receive reports of potentialmisconduct from any member of their staff are required to contact theCompliance Officer. All are advised to refrain from conducting an investigationon their own, or from taking any action to resolve the irregularity beforecontacting the Compliance Officer.All information regarding known or suspected financial misconduct is deemedprivileged and confidential. To the extent possible, the County will protect theidentity of both those who alert the County to any irregularity and thosesuspected of wrongdoing.

Investigation of Potential Financial Misconduct

All reports of potential financial misconduct will be promptly reviewed by theCompliance Officer. The Compliance Officer will evaluate necessary recordsand information to verify the validity of the reports and make a preliminarydetermination whether an investigation is warranted.When an investigation is in process, all departments are required to respondpromptly to inquiries initiated by the Compliance Officer and to provide accessto relevant records.The Compliance Officer will develop a risk assessment giving dueconsideration to the extent of possible financial consequences, any regulatory