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a. The Town finds that its mission as related to an internal control system is as follows:

(1) Provision of a democratic governmental structure at the grassroots level;

(2) Provision of services as determined through the political process including but not limited to police, fire, streets, roads, economic development, and parks;

(3) Promotion of government efficiency, accountability, reliability and transparency; and

(4) Promotion of safeguards to reduce the risk of loss due to fraud, waste, abuse, mismanagement or errors.

b. The Town finds that its interrelated and often overlapping objectives as related to an internal control system are as follows:

(1) Operations objectives which involve the ways governmental services are performed and the performance of those providing governmental services including by way of example budgeting, purchasing, permitting, cash management and planning among others.

(2) Reporting objectives which involve the filing of financial and nonfinancial information to those inside the government and those outside of the government including by way of example filing the annual report, audit and examination cooperation, filing uniform conflict of interest forms and the other filings with any governmental agency or official or information required to be kept such as an OSHA log and responding to a public records request among others.

(3) Compliance objectives involve the adherence to law and regulations including by way of example following guidance documents such as the State Board of Accounts’ manuals, bulletins, directives and the Department of Local Government Finance’s forms and directions and including other outside of government trainings and documents such as IACT among others, as appropriate for the Town of Clermont in that it has no full-time employees other than its elected officials and its Town Marshal and deputies.

c. The Town adopts and directs the minimum level of internal control standards and internal control procedures for an internal control system that includes the following five standards to promote government accountability and transparency as described in the Uniform Internal Control Standards for Indiana Political Subdivisions guidance document from the State Board of Accounts dated September 2015 and as thereafter modified:

(1) Control environment.

(2) Risk assessment.

(3) Control activities.

(4) Information and communication.

(5) Monitoring.

d. The Town adopts and directs the following principles in explanation of the pertinent standards above be followed at all levels of the Town government:

(1) Control Environment.

(i) The oversight body and management demonstrate a commitment to integrity and ethical values.

(ii) The oversight body oversees the Town’s internal control system.

(iii) Management establishes an organizational structure, assigns responsibility and delegates authority to achieve the Town’s objectives.

(iv) Management demonstrates a commitment to attract, develop and retain competent individuals.

(v) Management evaluates performance and holds individuals accountable for their internal control responsibilities.

(2) Risk Assessment.

(i) Management defines objectives clearly to enable the identification of risks and defines risk tolerances.

(ii) Management identifies, analyzes and responds to risk related to achieving the defined objectives.

(iii) Management considers the potential for fraud when identifying, analyzing and responding to risks.

(iv) Management identifies, analyzes and responds to significant changes that could impact the internal control system.

(3) Control Activities.

(i) Management designs control activities to achieve objectives and respond to risks.

(ii) Management designs the Town’s information system and related control activities to achieve objectives and respond to risks.

(iii) Management implements control activities through policies.

(4) Information and Communication.

(i) Management uses quality information to achieve the Town’s objectives.

(ii) Management internally communicates the necessary quality information to achieve the Town’s objectives.

(iii) Management externally communicates the necessary quality information to achieve the Town’s objectives.

(5) Monitoring.

(i) Management establishes and operates monitoring activities to monitor the internal control system and evaluate the results.

(ii) Management remediates identified internal control deficiencies on a timely basis.

e. The Town adopts the internal control standards above so as to establish an effective internal control system for the Town through its design, implementation and operation.

f. The Town directs that the above standards be used to design, implement, operate and modify current operations, reporting and compliance objectives that will safeguard the assets of the Town, promote reliability, accountability and transparency of financial and nonfinancial information and to assure compliance with laws and regulations for each office, department and personnel (as defined below) for an effective and reasonable internal control system of the Town.

g. The Town authorizes the Clerk-Treasurer, the Fiscal Commissioner, the Council President, and the Police Chief (Fiscal Committee) together with the advice of the Town Attorney to review the current internal control system of the Town and adopt a policy for the future internal control system, subject to the approval of the Town Council, to be effective after June 30, 2016, and perform an annual review, or more if determined necessary for compliance with this section.

h. The personnel, whether an official or employee, of the Town whose official duties include receiving, processing, depositing, disbursing, or otherwise having access to funds that belong to the federal government, state government, a political subdivision, or another governmental entity shall comply with these minimum internal control standards and procedures and any other policy regarding standards and procedures determined necessary by the Town now and as modified in the future.

i. The personnel of the Town, both elected and appointed, whose official duties include receiving, processing, depositing, disbursing, or otherwise having access to funds that belong to the federal government, state government, a political subdivision, or another governmental entity shall be trained at least once during a calendar year and annually thereafter, unless on leave status, on the minimum internal control standards and procedures and any other standards and procedures determined necessary by the Town and shall cooperate with the Town fiscal officer or designee so that the fiscal officer can timely certify to the State Board of Accounts that the training was received annually by the personnel as provided by law.

j. The Town authorizes the Fiscal Committee, subject to the approval of the Town Council, to determine the position and person who are the personnel referred to in subsections (h) and (i) of this section and notify such personnel.

k. The Town Council delegates to the Fiscal Committee, subject to Town Council approval, the authority and/or duties including creating the internal control systems policy.

l. All elected and appointed officials and employees of the Town are hereby directed to abide by and to cooperate fully in the implementation of the internal control system of the Town.

m. An employee who fails to abide by or cooperate with the implementation, compliance and certifications connected with the internal control system commits a violation thereof and may result in the discipline, including termination, of the employee.

n. An elected or appointed official of the Town who fails to abide by or cooperate with the implementation and the mandated certifications of the internal control system may be subject to any action allowed by law.

o. This section may be implemented by any and all of the following actions or such others as authorized by this Council: (1) posting a copy of the ordinance codified in this section in its entirety, in at least one of the locations in the Town where it posts employer posters or other notices to its employees; (2) providing a copy of the ordinance codified in this section to its employees and elected and appointed officials; (3) providing or posting a notice of the adoption of the ordinance codified in this section; or (4) any such other action or actions that would communicate the policies established by this section to its employees and elected and appointed officials. [Ord. 20160512-01 §§ 1 – 15, 2016.]