Hamilton Junior High School
Theft and Fraud Prevention Policy
Adopted by the Board of
Trustees on 16 December 2013
The Policy was approved and adopted by the Board at
its meeting held on 16 December 2013 and became effective from 1 January 2014
The Board accepts that it has a responsibility to protect the physical
and financial resources of the School. The Board has agreed that through its
chief executive, the Principal, the School has a responsibility to prevent and
detect theft and fraudulent actions by persons who are employed or contracted
by the School or who are service recipients of the School. The Board accepts
that any investigation into any theft or fraudulent actions will be conducted
in a manner that conforms to the principles of natural justice and is
procedurally just and fair.
The Board, therefore, requires the Principal to establish systems and
procedures to guard against the actions of theft and fraud. The Principal is to
report such actions to the Board Chairperson as prescribed in the procedures
set out below.
As preventative measures against theft and fraud the Board requires the
Principal to ensure that:
The School’s physical resources are kept secure and accounted for.
The School’s financial systems are designed to prevent and detect the
occurrence of fraud. All such systems must meet the requirements and standards
as set out in the Crown Entities Act 2004 and of generally accepted accounting
practice promulgated and supported by the Institute of Chartered Accountants of
Staff members who are formally delegated responsibility for the custody
of physical and financial resources by the Principal are proven competent to
carry out such responsibilities and that such persons are held accountable for
the proper execution of their responsibilities.
All staff members are aware of their responsibility to immediately
inform the Principal should they suspect or become aware of any improper or
fraudulent actions by staff, suppliers, contractors, students or other persons
associated with the School.
In the event of an allegation of theft or fraud the Principal shall act
in accordance with the following procedures:
Decide to either immediately report the matter to the New Zealand Police
or proceed as outlined in this paragraph.
So far as it is possible and within 24 hours:
Record the details of the allegation, the person or persons allegedly
involved, and the quantity and/or value of the theft or fraud.
Request a written statement
from the person who has informed the Principal, with details as to the nature
of the theft or fraud, the time and circumstances in which this occurred, and
the quantity and/or value of the theft.
Decide on the initial actions to be taken including consulting with the
person who provided the information and, if appropriate, confidentially
consulting with other senior members of staff about the person who is the
subject of the allegation.
Inform the Board Chairperson of the information received and consult
with them as appropriate.
On the basis of advice received and after consultation with the Board
Chairperson, the Principal shall decide whether or not a prima facie case of
theft or fraud exists, and if not, to document this decision and record that no
further action is to be taken.
The Principal shall then carry out the following procedures:
Investigate the matter further;
If a prima facie case is thought to exist to continue with their
Invoke any disciplinary procedures contained in the contract of
employment should the person be a staff member;
Lay a complaint with the New Zealand Police;
If necessary, commission an independent expert investigation;
In the case of fraud, require a search for written evidence of the
possible fraudulent action to determine the likelihood or not of such evidence;
Seek legal advice; or
Inform the Manager, National Operations, Ministry of Education local
office and/or the school’s auditors.
Once all available evidence is obtained the Principal shall consult the
Board Chairperson. The Board Chairperson may, if they consider it necessary,
seek legal or other advice as to what further action should be taken.
If a case is considered to exist the Principal or a person designated by
them shall, unless another course of action is more appropriate:
Inform the person in writing of the allegation that has been received
and request a meeting with them at which their representative or
representatives are invited to be present.
Meet with the person who is the subject of the allegation of theft or
fraud and their representatives to explain the complaint against them.
Obtain a verbal or preferably a written response (all verbal responses
must be recorded as minutes of that meeting, and the accuracy of those minutes
should be attested by all persons present).
Advise the person in writing of the processes to be involved from this
The Board recognises that supposed or actual instances of theft or fraud
can affect the rights and reputation of the person or persons implicated. All
matters related to the case shall remain strictly confidential with all written
information kept secure. Should any delegated staff member or any other staff
member improperly disclose information the Principal shall consider if that
person or persons are in breach of confidence and if further action is
required. Any action the Principal considers must be in terms of the applicable
conditions contained in their contract of employment and any code of ethics or
code of responsibility by which the staff member is bound.
The Board affirms that any allegation of theft or fraud must be subject
to due process, equity and fairness. Should a case be deemed to be answerable
then the due process of the law shall apply to the person or persons
Any intimation or written statement made on behalf of the School and
related to any instance of supposed or actual theft or fraud shall be made by
the Board Chairperson who shall do so after consultation with the Principal and
if considered appropriate after taking expert advice.
Allegations Concerning the Principal or a Trustee
Any allegation concerning the Principal should be made to the Board
Chairperson. The Chairperson will then investigate in accordance with the
requirements of paragraph 4 of this Policy.
Any allegation concerning a member of the Board of Trustees should be
made to the Principal. The Principal will then advise the manager of the local
office of the Ministry of Education and commence an investigation in accordance
with the requirements of paragraph 4 of this Policy.
When the Board approved the Policy it was agreed that no variations of
this Policy or amendments to it can be made except by the unanimous approval of
As part of its approval the Board requires the Principal to circulate
this Policy to all staff, and for a copy to be included in school’s Policy
Manual, copies of which shall be available to all staff. The school’s policy
manual shall also be made available to students and parents at their request.
The Board requires that the Principal arrange for all new staff to be made
familiar with this Policy and other policies approved by the Board.
behalf of, and with the authority of the Board on _________________