All Trustees, employees, vendors, contractors, agents, consultants, volunteers, and any other parties who are involved in the District's financial transactions shall act with integrity and diligence in duties involving the District's fiscal resources.

Note: See the following policies and/or administrative regulations regarding conflicts of interest, ethics, and financial oversight:

  • Code of ethics:
    • for Board members—BBF
    • for employees—DH
  • Financial conflicts of interest:
    • for public officials—BBFA
    • for all employees—DBD
    • for vendors—CHE
  • Compliance with state and federal grant and award requirements: CB, CBB
  • Financial conflicts and gifts and gratuities regarding federal funds: CB, CBB
  • Systems for monitoring the District's investment program: CDA
  • Budget planning and evaluation: CE
  • Compliance with accounting regulations: CFC
  • Activity fund management: CFD
  • Criminal history record information for employees: DBAA, DC
  • Disciplinary action for fraud by employees: DCD, DCE, and DF series

Fraud and Financial Impropriety

The District prohibits fraud and financial impropriety, as defined below, in the actions of its Trustees, employees, vendors, contractors, agents, consultants, volunteers, and others seeking or maintaining a business relationship with the District.


Fraud and financial impropriety shall include but not be 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 District assets, including employee time.

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

Profiteering as a result of insider knowledge of District information or activities.

Unauthorized disclosure of confidential or proprietary information to outside parties.

Unauthorized disclosure of investment activities engaged in or contemplated by the District.

Accepting or seeking anything of material value from contractors, vendors, or other persons providing services or materials to the District, except as otherwise permitted by law or District policy. [See CB, DBD]

Inappropriately destroying, removing, or using records, furniture, fixtures, or equipment.

Failure to provide financial records required by federal, state, or local entities.

Failure to disclose conflicts of interest as required by law or District policy.

Any other dishonest act regarding the finances of the District.

Failure to comply with requirements imposed by law, the awarding agency, or a pass-through entity for state and federal awards.

Financial Controls and Oversight

Each employee who supervises or prepares District financial reports or transactions shall set an example of honest and ethical behavior and shall actively monitor his or her area of responsibility for fraud and financial impropriety.

Fraud Prevention

The Superintendent or designee shall maintain a system of internal controls to deter and monitor for fraud or financial impropriety in the District.


Any fraud that is detected or suspected shall be reported immediately to the "Ethics Hotline," an anonymous toll-free fraud reporting service (855-400-6008); the employee's supervisor; the Superintendent; the chief financial officer; or the director of legal services. The director of legal services or the Superintendent's designee shall coordinate all investigations.

Concerns shall be reported in writing using the fraud disclosure form, which does not require a signature, or through the "Ethics Hotline."

Reports and any information regarding follow-up investigations shall be provided to the Board's Audit Committee. The Audit Committee shall work with the Superintendent and the director of legal services. If an allegation is made in good faith, but is not corroborated by the investigation, no action shall be taken against the person who files the allegation. Suspicious actions that do not constitute fraud must be reported in accordance with District procedures.

Protection from Retaliation

Neither the Board nor any District employee shall unlawfully retaliate against a person who in good faith reports perceived fraud or financial impropriety. [See DG]

Fraud Investigations

The director of legal services or the Superintendent's designee shall have the primary responsibility for investigating all suspected fraud or financial impropriety as defined in this policy. The Audit Committee may designate the investigation responsibilities in the event that both the Superintendent and the director of legal services are included in a report of suspected fraud. An employee shall not attempt to personally conduct investigations and shall not contact the suspected individual in an effort to determine facts or demand restitution.

Upon completion of the investigation, the director of legal services, the Superintendent's designee, or the designee of the Audit Committee shall submit a report of findings to the Superintendent, the Board President, the Board Audit Committee, and to other administrators, all as appropriate. The designee or director's report may contain a recommendation to refer the matter to appropriate law enforcement and/or regulatory agencies for independent investigation. The decision to make any such referral shall be made by the Superintendent or the Board as appropriate, in conjunction with legal counsel.

Federal Awards Disclosure

The District shall disclose, in a timely manner in writing to the federal awarding agency or pass-through entity, all violations of federal criminal law involving fraud, bribery, or gratuity violations potentially affecting a federal grant award. [See CBB]


The director of legal services and the Superintendent's designee shall treat as confidential all reports of suspected fraud or financial impropriety and all information obtained through an investigation. The District shall attempt to protect an individual's identity when a report is made and the individual does not want his or her name disclosed. The investigation process, however, may reveal the source of the information, and/or a statement by the individual may be required as part of the evidence. The District shall not tolerate harassment or victimization and shall take action to protect a person who raises a concern in good faith.

Investigation results shall not be disclosed or discussed with anyone other than those who have a legitimate need to know. Concerning the activity under investigation, all inquiries from the suspected individual, his or her attorney or representative, or any other inquirer shall be directed to the director of legal services.


In the course of an investigation of suspected fraud or financial impropriety, with proper notification of the appropriate level of management and in the presence of the appropriate administrator, the director of legal services or the Superintendent's designee shall have:

Free and unrestricted access to all District records, premises, and facilities, whether owned or rented by the District;

The authority to interview employees; and

The authority, when it is in the scope of the investigation, to examine, copy, and/or remove all documents, electronic data, files, tapes, disks, computers, and other equipment and storage facilities on the premises without prior knowledge or consent of any individual who may use or have custody of any such items or facilities.


If an employee is found to be engaging in or to have been engaged in fraudulent acts, or failed to report fraudulent acts, he or she shall be subject to disciplinary action, up to and including termination. Based on the seriousness of the offense, the results may be referred to the appropriate law enforcement and/or regulatory agencies.

[See BDB(LOCAL) for additional information regarding the Board Audit Committee]

Comal ISD



DATE ISSUED: 10/7/2015