g. In those instances where Division of Inspector General believes it to be in the best interests of the FRAUD, WASTE AND investigative audit, Division of Inspector General has the authority and duty, after consulting with ABUSE POLICY the Clerk of the Circuit Court, as applicable, to: OFFICE OF THE CLERK 1) take control/limit employee access, and/or OF THE CIRCUIT COURT gain full access to all Pinellas County premises utilized by the Clerk of the Circuit Court, whether owned or rented, and 2) examine, copy and/or remove all or any email@example.com portion of the contents of any document. 8. MANAGEMENT RESPONSIBILITIES 8.1 Great care must be taken in the investigative audit of suspected improprieties or irregularities so as to avoid mistaken accusations or alerting suspected individuals that an investigative audit is under way. a. All inquiries from suspected individuals and their Write: attorneys or representatives should be directed to Division of Inspector General. Proper response Public Integrity Unit to such an inquiry is: “I am not at liberty to discuss Division of Inspector General this matter.” Fraud Hotline b. Under no circumstances should any reference be 510 Bay Avenue made to “what you did,” “the crime,” “the fraud,” Clearwater, FL 33756 “the forgery,” “the misappropriation” or any other specific reference. Call: c. No promises should be made. Fraud Hotline 8.2 Management/employees should not contact the Phone: (727) 453-3728 suspected individual in an effort to determine facts or demand restitution. Fax: (727) 464-8386 8.3 Management/employees are encouraged not to discuss the case, facts, suspicions or allegations with E-mail: anyone outside the organization or those within the firstname.lastname@example.org organization who do not have a legitimate need to know unless specifically asked to do so by Division of Internet: Inspector General or law enforcement. www.mypinellasclerk.org 8.4 Management/employees are required to cooperate An independent service offered by the Clerk of the www.twitter.com/pinellasig with the investigative audit process through Circuit Court of Pinellas County. The Division of answering questions, furnishing of written www.facebook.com/igpinellas Inspector General assists the Clerk in fulfilling an statements, volunteering information important to oversight responsibility as well as in finding methods the investigative audit, etc. to enhance county government operations. 8.5 All Clerk of the Circuit Court departments/employees These contacts may also be used are required to comply with this policy. to report cases involving fraud or 9. LIMITATION waste of a ward’s assets. Nothing in this directive or policy shall be construed to interfere with, limit, restrict or otherwise impair the Clerk Ken Burke, CPA of the Circuit Court’s or any official’s ability to manage, Clerk Of The Circuit Court train, assign or discipline their employees. 03/11 Pinellas County, Florida 1. POLICY 4.2 Waste refers to the unnecessary incurring of costs as 7.2 A current or former Pinellas County employee who The Pinellas County Clerk of the Circuit Court’s Fraud, a result of inefficient practices, systems or controls. suspects fraud, waste or abuse, and wishes to remain Waste and Abuse Policy and Procedures are established anonymous, should: 4.3 Abuse refers to violations and circumventions of to facilitate the development of internal controls that a. Contact the Fraud Hotline and provide as much departmental or agency regulations which impair will provide for the detection, prevention and reporting detailed information as possible regarding the the effective and efficient execution of operations. of fraud, waste and abuse directed against county suspected fraudulent conduct. government. It is the intent of this policy to promote awareness of the potential for fraud, waste and abuse 5. INVESTIGATIVE AUDIT RESPONSIBILITIES b. The caller, though anonymous, must be willing to throughout the county government, and to provide 5.1 The Clerk of the Circuit Court, Division of Inspector share specific information regarding the suspected guidelines and assign responsibility for the development General has the primary responsibility for investiga- fraudulent conduct. of adequate internal controls and systems. tive audits of all suspected inappropriate activity 7.3 A member of the public suspecting fraud, waste or as defined in this policy. If the investigative audit abuse, is encouraged to contact the Fraud Hotline It is the policy of the Pinellas County Clerk of the Circuit substantiates that a fraudulent act has occurred, Court to ensure compliance with the principles of right with specific and detailed information regarding the Division of Inspector General will notify the Clerk suspected fraudulent conduct. and wrong which govern the conduct of county of the Circuit Court, or Pinellas County Administra- employees, vendors, consultants, contractors and all tor as applicable, and such other County officials as 7.4 A supervisor or higher authority receiving a fraud other outside agencies/parties doing business with appropriate. If the substantiated fraudulent act has allegation should: Pinellas County. This policy is intended to communicate criminal implications, Division of Inspector General a. Compile all information relayed by the reporting the Clerk of the Circuit Court’s desire to eliminate will consult with law enforcement agencies as nec- individual. unethical practices while creating an environment in essary to assist in the preparation and presentation which employees and/or citizens are encouraged and b. Contact Division of Inspector General with all of criminal findings in a court of law. compiled information. comfortable in the reporting of fraud, waste or abuse. 5.2 Division of Inspector General, through authorization c. Cooperate with the investigative audit process. The law in Florida protects employees from retaliatory or adverse personnel action for disclosing certain of the Clerk of the Circuit Court, is hereby authorized 7.5 Division of Inspector General will: information, including, but not limited to, violations of to make investigative audits into Pinellas County affairs and for that purpose may administer oaths a. Maintain a Fraud, Waste and Abuse Hotline, and laws which create and present a substantial and specific and compel the production of books, papers and attempt to secure as much information as possible danger to the public’s health, safety or welfare and other evidence material to said inquiry. from the reporting individual. suspected acts of gross mismanagement or gross waste of public funds. These protections are detailed in Sections b. Contact law enforcement, as appropriate in the 112.3187-112.31895 of the Florida Statutes. 6. CONFIDENTIALITY circumstances, and provide fraud, waste and Division of Inspector General treats all information abuse information for consideration as to their 2. PURPOSE received confidentially, to the extent allowed by law. involvement in the case. This directive provides instruction and guidance for Any employee, citizen, contractor, vendor or other c. Evaluate reported conduct pertaining to any and implementing the Fraud, Waste and Abuse Policy interested party who has observed or suspects dishonest all departments of Pinellas County and such other adopted by the Clerk of the Circuit Court. or fraudulent activity should notify the Fraud Hotline activities/entities engaged in the expenditure of immediately. Persons observing or suspecting dishonest county funds. 3. SCOPE or fraudulent activity should not attempt to personally This directive is applicable to all Pinellas County Clerk of conduct an investigation related to such activity. d. Report investigative audit findings to the County the Circuit Court employees. Administrator or Clerk of the Circuit Court, as applicable, in an interim report. If interim findings 7. PROCEDURES 4. DEFINITIONS are of a countywide nature or are otherwise 7.1 A current or former Pinellas County employee who 4.1 Fraud refers to, but is not limited to, any dishonest significant, the Board of County Commissioners suspects fraud, waste or abuse, and does not desire or fraudulent act to include forgery or alteration may also be notified if any of their personnel are anonymity, should: of any document; misappropriation of funds, involved. supplies, etc.; improper handling or reporting of a. Report the suspected fraud to the Fraud Hotline. e. Report any significant findings to the County money or financial transactions; profiting by self or b. If requested, furnish a detailed written statement, Administrator, Clerk of the Circuit Court and Board others as a result of inside knowledge; destruction under oath, outlining the suspected fraud. of County Commissioners, as applicable, in a final or intentional disappearance of records, furniture, report. fixtures or equipment; accepting or seeking anything c. Cooperate with the investigative audit process through the furnishing of written statements, f. Work with law enforcement authorities as of material value from vendors or persons providing determined necessary during the course of the services or materials to Pinellas County for personal interviews, etc. investigative audit and refer applicable findings to benefit; and/or any similar or related irregularity. appropriate authorities upon completion.