1. Create a written Code of Conduct that addresses routine and non-routine situations staff will encounter in performing their work. Provide examples, short cases and answers to Frequently Asked Questions. Be wary of boilerplate terminology. Focus instead on meaningful real-world guidance for conduct.
2. Due to limitations in staffing and inadequate segregation of duties controls, managers should compensate by spot checking and re-performing the work of subordinates. Make this ‘quality check’ a daily habit.
3. Require that approvers carefully review all disbursement documentation prior to approval. Verify details, ask questions, and when in doubt, choose to doubt and follow up until a valid verifiable conclusion is reached.
4. Have bank account and credit card statements sent unopened directly to the chief executive. This executive should review all statements in detail as soon as they are received.
5. Verify the existence and legitimacy of all first-time payment recipients.
6. Make everyone take uninterrupted vacations or other time away from their jobs. Have other staff fill in for them and complete their work while they are away.
7. You simply must perform meaningful criminal background checks on employees and many volunteers. There’s no easy way around this one. Those terminated for cheating at past employers know they need a new job right now. No delay. And prime targets for new jobs for these folks are the smaller business, governmental entity or not-for-profit that everyone knows has limited resources and staff to check backgrounds.
Comply with the privacy, anti-discrimination and other applicable laws. Get competent legal advice and find a way to get these reviews done! (see Consideration of Arrest and Conviction Records in Employment Decisions for one source of guidance)
John J. Hall, CPA, is an author, speaker and results expert who presents around the world at conventions, corporate meetings and association events. Throughout his 35-year career as a business consultant, corporate executive and professional speaker, John has helped organizations and individuals achieve measurable results. He inspires audience members in corporations, not-for-profit organizations and professional associations to step up, take action and “do what you can.”