700 PURPOSE OF NON-INSTRUCTIONAL AND BUSINESS SERVICES

The school district's non-instructional services and business operations assist in the delivery of the education program and include, but are not limited to, transportation, the school lunch program, and child care.

The Board, as it deems necessary, will provide additional non- instructional services to support the school district’s education program. It shall be the goal of the Board to provide non-instructional services and to conduct its business operations and use of public funds in an efficient manner.

Expenditure for Public Purpose

The Board recognizes and supports the principle that District funds are to be expended only for legitimate public purposes and not for private personal gain for which services of comparable value have not been rendered to the District. The Board of Directors believes it is important to designate those expenditures for officers, directors, employees, and volunteers, which are in addition to salaries and benefits authorized and/or specified in Code 400 and legitimate expense reimbursements, which serve a legitimate public purpose. 

The Board authorizes the expenditure of District funds for District officers, directors, employees, and volunteers for the following purposes, as these are commonly-granted benefits for employees and volunteers in public and private organizations which aid in recruitment of personnel, promote improvement of staff morale and cooperation, assist in building a commitment to the District, and improve employee and business efficiency, thus assisting in creating a more productive learning environment: 

The Board also authorizes the expenditure of District funds for coffee and soft drinks in the school buildings. Coffee, soft drinks, and light refreshments, may also be made available at Board and committee meetings to promote a welcoming environment and as a common courtesy for individuals who travel to the District building for attendance at District meetings and conferences. 

No District funds will be used to pay the cost of any alcoholic beverage and no alcoholic beverage will be available on school grounds.

Legal References: Iowa Constitution Article III, Section 31; 279.8, 721.2(5) Code of Iowa

 

*Reviewed:  04/08/02

*Reviewed:  01/29/07

*Reviewed:  04/12/10

*Revised:  12/13/10

*Reviewed: 10/13/14

*Reviewed: 12/10/18

*Revised: 02/10/20

700.1 Internal Controls & Whistleblower

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

Internal control is the responsibility of all employees of the District.  The Superintendent, chief financial officer, business manager and Board secretary [or designee] shall be responsible for developing internal controls designed to prevent and detect fraud, financial impropriety, or fiscal irregularities within the 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 the Superintendent, the business manager, the human resources director, or a Finance/Audit Committee member.  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 termination.

In the event the concern or complaint about a potential financial impropriety involves the Superintendent, the concern shall be brought to the attention of the Board Vice President 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.

As the elected leader of the Board, the Board President shall manage the Board and related actions including Board meetings, analysis of information related to concerns and/or complaints, and all communication internally and externally to the district.

Upon approval of the Board, the Superintendent [or designee] may contact the state auditor or elect to employ the school district’s auditing firm or state auditor to conduct a complete or partial forensic/internal control/SAS99 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 state auditor is notified of any suspected embezzlement or theft pursuant to Iowa 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.

 

*Adopted: 02/10/20

 

700.1R Administrative Regulations Regarding Internal Control Procedures and Whistleblower Complaints

Fraud, financial improprieties, or irregularities include but are not limited to:

  • Forgery or unauthorized alteration of any document or account belonging to the district.

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

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

  • Impropriety in the handling of money or reporting of financial transactions.

  • Profiteering because of insider information of district information or activities.

  • Disclosing confidential and/or proprietary information to outside parties.

  • Accepting or seeking anything of material value other than items used in the normal course of advertising from contractors, vendors, or persons providing services to the district.

  • Destroying, removing, or inappropriately using district records, furniture, fixtures, or equipment.

  • Failing to provide financial records to authorized state or local entities.

  • Failure to cooperate fully with any financial auditors, investigators, or law enforcement.

  • Any other dishonest or fraudulent act involving district monies or resources.

The Superintendent [or designee] shall investigate reports of fraudulent activity in a manner that protects the confidentiality of the parties and the facts.  All employees involved in the investigation shall be advised to keep information about the investigation confidential.

The employee bringing forth such actions in good faith to the Superintendent, the business manager, the human resources director or a Finance/Audit Committee Member, may not be discharged, threatened, or otherwise discriminated against regarding the employee’s compensation, terms, conditions, location, or privileges of employment. The employee must exercise sound judgment to avoid baseless allegations. An employee who intentionally files a false report of wrongdoing will be subject to disciplinary action.

If an investigation substantiates the occurrence of a fraudulent activity, the Superintendent, or Board Vice President if the investigation centers on the Superintendent, shall issue a report to the Board and appropriate personnel.  The final disposition of the matter and any decision to file or not file a criminal complaint or to refer the matter to the appropriate law enforcement and/or regulatory agency for independent investigation shall be made in consultation with district legal counsel.  The results of the investigation shall not be disclosed to or discussed with anyone other than those individuals with a legitimate right to know until the results are made public.

 

*Adopted: 02/10/20