Kentucky Housing Corporation recognizes the importance of protecting the organization, its operations, its employees and its assets against financial risks, operational breaches and unethical activities. Therefore, it is incumbent upon Kentucky Housing’s Board of Directors and management to institute and clearly communicate the fraud prevention policy to both internal and external customers, vendors and partners.
Kentucky Housing recognizes a zero tolerance policy regarding fraud and corruption. All matters raised by any source will be taken seriously and properly investigated.
This policy covers all Kentucky Housing employees and officers. Additionally, this policy covers all Kentucky Housing vendors, customers and partners to the extent that any Kentucky Housing resources are involved or impacted.
Fraud is defined as an intentional deception, misappropriation of resources or the manipulation of data to the advantage or disadvantage of a person or entity. Some examples of fraud include:
- Falsification of expenses and invoices
- Theft of cash or fixed assets
- Alteration or falsification of records
- Failure to account for monies collected
- Knowingly providing false information on job applications and requests for funding
Corruption is defined as the offering, giving, soliciting or accepting of an inducement or reward that may improperly influence the action of a person or entity. Some examples of corruption include:
Reporting of Fraud or Corruption
Allegations and concerns about fraudulent or corrupt activity may come from various sources including:
- Members of the public
- Results of internal or external audit reviews
- Any other interested parties
All employees and officers have a duty to report concerns they have or information provided to them about the possible fraudulent or corrupt activity of any officer, employee, vendor or any other party with any association with Kentucky Housing. Any person who has a reasonable basis for believing fraudulent or corrupt acts have occurred has a responsibility to report the suspected act immediately.
Concerns should be reported to any of the following:
Retaliation and retribution will not be tolerated against any employee or officer who reports suspected fraudulent or corrupt activities. However, if an employee is determined to have acted maliciously or with deceit, the employee will be subject to disciplinary action.
All reports will be taken seriously and will be investigated by Internal Audit staff and/or the Legal Department. If deemed necessary, Kentucky Housing will notify and fully cooperate with the appropriate law enforcement agency. Any investigation resulting in the finding of fraud or corruption will be referred to the Kentucky Housing Disciplinary Committee for action. The Disciplinary Committee is composed of Kentucky Housing Corporation’s general counsel, director of Internal Audit, director of Human Resources and the chief executive officer. Fraudulent or corrupt activities that result in disciplinary action will be reported to the Board of Directors.
Deterring Fraud and Corruption
Kentucky Housing has established internal controls, policies and procedures in an effort to deter, prevent and detect fraud and corruption.
All new employees, plus temporary and contract employees, are subject to background investigations including a criminal background check. Kentucky Housing will also verify all applicants’ employment history, education and personal references prior to making an offer of employment.
All vendors, contractors and suppliers must be active, in good standing and authorized to transact business in the Commonwealth of Kentucky. Vendors, contractors and suppliers are subject to screening, including verification of the individual’s or company’s status as a debarred party.
All contractual agreements with Kentucky Housing will contain a provision prohibiting fraudulent or corruptive acts and will include information about reporting fraud and corruption.
Kentucky Housing employees will receive fraud and corruption awareness training. New employees will receive training as part of orientation at the commencement of employment. All employees will receive fraud and corruption awareness training every two years.
Final determination regarding action against an employee, vendor, recipient or other person found to have committed fraud or corruption will be made by the Disciplinary Committee.
Offenders at all levels of the Corporation will be treated equally regardless of their position or years of service with Kentucky Housing. Determinations will be made based on a finding of facts in each case, actual or potential damage to the Corporation, cooperation by the offender and legal requirements.
Depending upon the seriousness of the offense and the facts of each individual case, action against an employee can range from written reprimand and a probationary period to legal action – either civil or criminal. In all cases involving monetary losses to Kentucky Housing, Kentucky Housing will pursue recovery of losses.