Financial Regulation

Cheque Signing

Purpose

To spell out procedures that must be followed in the signing of cheques on behalf of Wood Street Walls

Policy

All cheques issued on behalf of the organisation must be signed by a sufficient number of authorised persons as outlined in the company bank account’s T&Cs and documented adequately.

Responsibilities

It is the responsibility of the CEO to ensure that:
staff are aware of this policy;
any breaches of this policy coming to the attention of management are dealt with appropriately.

It is the responsibility of the employees and volunteers to ensure that their usage of organisational cheques conforms to this policy.

Processes

All cheques must contain two eligible signatures. Eligible signatories are Mark Clack and Tom Jackson - Co-Founders - and Milli Richards, Treasurer.

Any two of the above have the authority to sign cheques.

Signatories cannot sign a cheque made payable to themselves, or a blank cheque. All details on the cheque form must be filled in before signature.

A list of all cheques issued each month, featuring amount, recipient, signatories, and explanation, will be provided to the Treasurer.

Authorisation
[Signature of Board Secretary]
[Date of approval by the Board]
[Name of Organisation]

Reimbursement of Expenses

Purpose

The purpose of this policy is to spell out under what circumstances reimbursement of expenses may occur on behalf of Wood Street Walls, and the process for doing so. This policy relates to both staff and volunteers acting on authorized Wood Street Walls business.

Policy

Wood Street Walls will reimburse its staff (including volunteers) expenses incurred by them on behalf of Wood Street Walls or in the course of Wood Street Walls business so long as such expenses are:
Reasonable and
Authorised.

Reimbursement of reasonable but unauthorised expenses may be made on an ex gratia basis at the discretion of Mark Clack and Tom Jackson in exceptional circumstances only.

Staff and volunteers incurring authorised expenditure must, wherever possible, receive, retain and produce receipts, invoices, vouchers, tickets, or other evidence of such expenditure.

Responsibilities

It is the responsibility of Management to ensure that:
Staff and volunteers are aware of this policy;
Any breaches of this policy coming to the attention of management are dealt with appropriately.

It is the responsibility of the all employees and volunteers to ensure that their applications for reimbursement conform to this policy.

Procedures

Prohibited reimbursements

Wood Street Walls will not reimburse staff or volunteers for:
Unauthorised expenses
Expenses claimed by an employee as a tax deduction
Expenses normally recoverable from a third party
Claims for purchases that are required to be made under a Wood Street Walls purchase order
Expenses that are not incurred for business purposes
Late payment interest on credit cards
Parking, traffic, or other fines and penalties

Travel expenses

Employees and volunteers will be reimbursed for the most direct and economical mode of travel available, considering all of the circumstances.
Employees and volunteers will not be reimbursed for additional costs incurred by taking indirect routes or making stopovers for personal reasons.
Use of an employee or volunteer’s own vehicle for work-related travel will be reimbursed by way of an all-inclusive mileage allowance, as shall be determined by the organisation from time to time.
Trip cancellation insurance is eligible for reimbursement.

Accommodation expenses

Employees and volunteers will be reimbursed for moderate accommodation expenses, considering all of the circumstances. Where possible Wood Street Walls will host volunteers to reduce accommodation expenses.
Employees and volunteers will not be reimbursed for items of a personal nature charged to a hotel account.
When accommodation is provided by an employee’s friend or relative, to whom the employee or volunteer gives money or a gift as compensation or as a sign of appreciation, the employee or volunteer may claim an overnight accommodation expense in accordance with per diem rates, as shall be determined by the organisation from time to time.

Meals

Employees and volunteers will be reimbursed for reasonable and appropriate meal expenses actually incurred while on Wood Street Walls business.

Provision of hospitality

Employees and volunteers will be reimbursed for hospitality expenses incurred in the course of Wood Street Walls business, as appropriate.
Appropriate hospitality charges include events hosted or sponsored for the purpose of promoting Wood Street Walls’s work or enhancing its image, and include meals that are related to the transaction of Wood Street Walls business.
When Wood Street Walls employees and/or volunteers dine together while on Wood Street Walls business, it is appropriate for the senior person (if any) to arrange payment and submit the claim for reimbursement.

Terms & Conditions

Advance payments may be authorised where appropriate. Such payments will be subtracted from the amount of any later reimbursements. If expenditure is, for whatever reason, not incurred then any advance payments made, or any unspent portion of such payments, must be returned.
Fixed per diem payments may be authorised where appropriate.
Staff are authorised to approve expenses to the amount specified in their individual job statement, and for expenditure above this level must seek specific authorisation from their supervisors.
Except where per diem payments have been authorised, staff and volunteers incurring authorised expenditure must, wherever possible, receive and retain receipts, invoices, vouchers, tickets, or other evidence of such expenditure.
Staff and volunteers incurring authorised expenditure must submit requests for reimbursement to the designated person (depending on the sum in question) on the standard form (see Appendix A, describing the nature and purpose of the expenses. The completed form must be signed by the applicant.)
Except where per diem payments have been authorised, staff and volunteers incurring
authorised expenditure must present all relevant original receipts, invoices, vouchers, tickets, or other evidence of such expenditure when seeking reimbursement. Where such evidence is for any reason lacking, statutory declarations may be sought.
Managers are responsible for determining if the expenses being claimed are reasonable given the circumstances, and for ensuring they are charged against the appropriate account, and that any requirements under the Fringe Benefits Tax legislation have been met.
Claims that have not been properly prepared, authorised, or supported by adequate documentation will be returned to the claimant and the reasons will be given for not processing the claim.

Financial Transaction Cards

Purpose

The purpose of this policy is to:
ensure that organisational transactions are carried out as efficiently as possible through the use of credit cards and transaction cards as appropriate.
guard against any possible abuse of organisational transaction cards.

Policy

Transaction cards issued to Wood Street Walls, including those held in the name of any staff, volunteers or officers on behalf of the organisation, will only be used for those activities that are a direct consequence of the cardholders’ function within the organisation. Their use will be monitored according to the procedures listed below. Any use of the card inconsistent with this policy and these procedures will be grounds for dismissal.

Responsibilities

It is the responsibility of the Co-Founders to ensure that:
staff and volunteers are aware of this policy;
any breaches of this policy coming to the attention of management are dealt with appropriately.
It is the responsibility of the all employees and volunteers to ensure that their usage of credit cards conforms to this policy.

Processes

1. Card Issue

Any organisational financial transaction cards may only be issued by a board member, staff member, or volunteer where their functions and duties would be enhanced by their use. Cards will thus be issued only to people on the approved Organisational Financial Transaction Card List. The list shall be held by the Co-Founders.
Other persons may be added to the list by the Board. The Board may delegate the power to add persons to the list to any or all of:
The Finance Committee;
The CEO;
The auditor.
Cards may be issued on a temporary basis and recovered afterwards.
Each financial transaction card will be issued to a specific person, who will remain personally accountable for the use of the card. Cardholders will sign a declaration to this effect.
Only the authorised signatory may use the card. No more than one card shall be issued per cardholder. Credit limits as appropriate shall be set for each card by the issuing authority.

2. Cardholder’s Responsibilities

The Cardholder shall:
In all cases obtain and retain sufficient supporting documentation to validate the expense (e.g. tax invoice) or shall in lieu provide a statutory declaration.
Attach supporting documentation to the monthly statement from the bank.
Review the monthly statement for inaccuracies (and report these to the Co-Founders).
Verify that that goods and services listed were received.
Sign the monthly statement to verify that transactions have been made for official purposes.
Forward the papers to the authorised signatory for approval (Co-Founders).
Notify the bank and the Co-Founders immediately if
The card is lost or stolen; and/or
Any unauthorised transaction is detected or suspected.
Notify the Co-Founders and the bank of any change in name or contact details.
Take adequate measures to ensure the security of the card.
Return the card to the Co-Founders if
The cardholder resigns;
The Co-Founders determine that there is no longer a need for the cardholder to retain his or her card; or
The card has been cancelled by the bank.
Be personally liable for any unauthorised transaction unless the card is lost, stolen or subject to fraud on some part of a third party.

The Cardholder shall not:
Exceed any maximum limits set for the card from time to time.
Obtain cash advances through the card.
Use the card for any proscribed purchases.
Authorise their own expenditure.
Claim double allowances (i.e. request reimbursement for an expense already paid by the card).

3. Card Expenditure

The card will only be used for those activities that are a direct consequence of the cardholders’ function within the organisation.
Where coincident and/or private expenditure occurs on the same transaction (where, for example, a person incurs a debt for personal telephone calls during a hotel stay) the cardholder must settle the private expense prior to charging the balance on the organisational card.
Where doubt exists as to whether or not an item is function-related, prior authorisation should be obtained from the Co-Founder (or, in the case of the CEO’s own card, the Board or the person of the Finance Committee).
The use of the corporate card for “services of a dubious nature” is expressly prohibited. “Services of a dubious nature” are defined as any goods or services that might bring the name of the organisation into disrepute.

4. Card Misconduct

Wherever a breach in this policy occurs, the Co-Founders must assess the nature of the breach and, if significant, report the breach to the police for criminal investigation or, if lesser in nature, institute an appropriate disciplinary process:
in the first instance, counselling and or verbal warning (and diary or file note created);
in the second instance, a written warning;
in the third instance, or if the dollar amount is greater than $1000, the card is to be immediately withdrawn.
At the next Finance Committee meeting the Co-Founders shall report:
the investigation of the circumstances of the breach
police reports and action (if any)
disciplinary action taken (if any)

Fraud Risk Management

Purpose

The purpose of this policy is
To ensure that all parties are aware of their responsibilities for identifying exposures to fraudulent activities and for establishing controls and procedures for preventing such fraudulent activity and/or detecting such fraudulent activity when it occurs.
To provide guidance to staff/volunteers/contractors as to action which should be taken where they suspect any fraudulent activity.
To provide a clear statement to staff/volunteers/contractors forbidding any illegal activity, including fraud for the benefit of the organisation.
To provide assurance that any and all suspected fraudulent activity will be fully investigated.

Policy

Wood Street Walls will not tolerate fraud in any aspect of its operations.
Wood Street Walls will investigate any suspected acts of fraud, misappropriation or other similar irregularity. An objective and impartial investigation, as deemed necessary, will be conducted regardless of the position, title, length of service or relationship with the organisation of any party who might be the subject of such investigation.
Any fraud shall constitute grounds for dismissal. Any serious case of fraud, whether suspected or proven, shall be reported to the police. Any person reporting a fraud, or a
suspected fraud, shall suffer no penalty in their employment.

Responsibilities

The Board of Wood Street Walls has ultimate responsibility for the prevention and detection of fraud and is responsible for ensuring that appropriate and effective internal control systems are in place.
The Co-Founders are responsible for investigating instances of fraud reported to them.
All managers must ensure that there are mechanisms in place within their area of control to:
Assess the risk of fraud;
Educate employees about fraud prevention and detection; and
Facilitate the reporting of suspected fraudulent activities.
Management should be familiar with the types of improprieties that might occur within their area of responsibility and be alert for any indications of such conduct.
All staff/volunteers/contractors share in the responsibility for the prevention and detection of fraud in their areas of responsibility.
All staff/volunteers/contractors have the responsibility to report suspected fraud.
Any staff member, volunteer or contractor who suspects fraudulent activity must immediately notify their supervisor or those responsible for investigations.
In situations where the supervisor is suspected of involvement in the fraudulent activity, the matter should be notified to the next highest level of supervision or to the Co-Founder.

Processes

Fraud prevention accounting procedures shall be incorporated in the organisation’s policies relating to Authority to Sign Cheques, Reimbursement of Expenses, Financial Transaction (credit and debit) Cards, Acceptable Use of Computers, Acceptable Use of Vehicles and Equipment, Cash Management & Income Handling, and any other relevant policies.

Fraud prevention procedures shall be incorporated in the organisation’s policies relating to Staff Recruitment and Staff Induction.
All complaints of suspected fraudulent behaviour must be reported to the Co-Founders.
Upon notification or discovery of a suspected fraud, the Co-Founders will promptly arrange to investigate the fraud. The CEO will make every effort to keep the investigation confidential; however, from time to time other members of the management team will need to be consulted in conjunction with the investigation.
After an initial review and a determination that the suspected fraud warrants additional investigation, the Co-Founders shall coordinate the investigation with the appropriate law enforcement officials. Internal or external legal representatives will be involved in the process, as deemed appropriate.
Once a suspected fraud is reported, immediate action will be taken to prevent the theft, alteration, or destruction of relevant records needs to occur. Such actions include, but are not necessarily limited to, removing the records and placing them in a secure location, limiting access to the location where the records currently exist, and preventing the individual suspected of committing the fraud from having access to the records.
Where a prima facie case of fraud has been established the matter shall be referred to police. Any action taken by police shall be pursued independent of any employment-related investigation by the organisation.
If a suspicion of fraud is substantiated by the investigation, disciplinary action, up to and including dismissal, shall be taken by the appropriate level of management.
The organisation will also pursue every reasonable effort, including court ordered restitution, to obtain recovery of the losses from the offender.
Vendors and contractors shall be asked to agree in writing to abide by these policies and procedures.
No employee of the organisation, or person acting on behalf of the organisation in attempting to comply with this policy shall:
be dismissed or threatened to be dismissed;
be disciplined or suspended or threatened to be disciplined or suspended;
be penalised or any other retribution imposed, or
be intimidated or coerced,

• based to any extent upon the fact that the employee has reported an incident or participated in an investigation in accordance with the requirements of this Policy. Violation of this section of the Policy will result in disciplinary action, up to and including dismissal.
  If an allegation is made in good faith, but it is not confirmed by the investigation, no action will be taken against the originator.