Membership in PEBA offers several privileges that should not under any circumstances be abused or misused. They are:

1. Membership Directory and Access to Membership Database
   Membership information is provided to facilitate the exchange of information and dialog between members. We respect and appreciate the need to market services and products to members, but we ask that members refrain from using the membership directory to conduct mass marketing campaigns. Under no circumstances should membership information be reprinted or sold.

2. Access to Program Materials
   Printed copies of program presentations are typically distributed to participants and posted in the Members Only section of the PEBA website. These materials are the intellectual property of the author and may come under copyright law. They are provided to PEBA and its members strictly for educational purposes. Program materials should not be reprinted and distributed without the permission of the author and PEBA.

3. Recruiting Employees
   PEBA encourages the professional exchange of employment opportunities and needs through our website's PEBA Job Board. In fact, PEBA can be a tremendous resource for members who are between jobs and seeking a position. However, recruiters and search firms are asked to refrain from openly and actively recruiting during PEBA functions.

4. PEBA Listserv and Ask the Expert Page
   PEBA provides several avenues for members to exchange knowledge and resources; e.g. Listserv and Ask the Expert. Members should refrain from using these tools to conduct personal job searches, solicit business, market services, or solicit/provide negative comments about service providers.

5. Volunteer Opportunities
   The success of PEBA depends on the support and dedication of its members. Members of the Board, committee chairs, and committee volunteers must demonstrate the highest professional conduct and ethical standards.

Violation of any part of the PEBA Code of Conduct may be grounds for revocation of membership in PEBA. A membership may be revoked by a majority vote of the Board at any regular Board meeting. There are no refunds for a revoked membership. If a membership has been revoked, a two-year waiting period must be observed before reapplying to PEBA.

Anti Fraud Policy and Response Program 

Introduction
The Organization’s staff and Board of Directors are committed to conduct business pursuant to the highest ethical standards.  The Organization will apply these ethical standards through the oversight of the Board and its committees; management's practices; organizational structure; hiring and promotional practices; training and education; employee, constituency and community relationships; and policies and procedures.  This will provide a work environment that is conducive to both individual and organizational success.

Purpose
This Anti-Fraud Policy and Response Program (“Policy”) has been created to support the Organization’s commitment to protecting its revenue, property, reputation and other assets; to emphasize clearly the need for accurate financial reporting; and to define guidelines for the investigation and handling of fraud, should it occur. 

Applicability
This Policy applies to all employees of the Organization. This includes all full-time, part-time, seasonal and other temporary employees. 

Definition of Fraud
In law, "fraud" generally involves an act of deception, bribery, forgery, extortion, theft, misappropriation, false representation, conspiracy, corruption, collusion, embezzlement, or concealment of material facts.  Fraud may be committed by an individual, a group of individuals, or by one or more organizations, and is a violation of trust that, in general, refers to an intentional act committed to secure personal or business advantage.

While fraud can cover many activities, this Policy is directed primarily at financial matters that could be legally defined as fraud.  Examples of "financial fraud" generally fall into four broad categories and may include, but are not limited to:

 1. Misappropriation of assets 

• Forgery, alteration or misappropriation of checks, drafts, promissory notes or securities

• Unauthorized, non-business acquisition, use, or disposition of funds, inventory, furniture, fixtures, equipment, records, or other assets

• Embezzlement

• Theft

• Falsifying time sheets or payroll records, including but not limited to reporting hours not worked or a supervisor not allowing the reporting of all hours worked by hourly employees

• Falsifying travel and entertainment expenses and/or utilizing organization funds to pay for personal expenses

• Fictitious reporting of receipts

• Misappropriation of organization-owned computer hardware, software, data, or other records including company intangibles (e.g. proprietary information, etc.)

2. Fraudulent Financial Reporting

• Earnings management

• Improper revenue recognition

• Overstatement of assets

• Understatement of liabilities

3. Expenditures and Liabilities for Improper Purposes

• Bribery

• Kickbacks

4. Fraudulently Obtained Revenue and Assets

• Improper tax reporting

General Policy and Responsibilities

1. It is the Organization’s intent to 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 Organization of any party who might be or becomes involved in or becomes/is the subject of such investigation.
   
    

2. Management is responsible for instituting and maintaining a system of internal control to provide reasonable assurance for the prevention and detection of fraud, misappropriations and other irregularities.  Management will be familiar with the types of improprieties that might occur and be alert for any indications of such conduct.
   
    

3. The Finance Committee, with consultation and support from Management, has the primary responsibility for overseeing the investigation of all activity as defined in this policy, as appropriate.
   
    

4. Upon conclusion of the investigation, the results will be reported to the Executive Committee of the Board of Directors.
   
    

5. Where there are reasonable grounds to indicate that a fraud may have occurred, the Organization may report the incident to the appropriate authorities in order to pursue all legal remedies. Also, the Organization will pursue every reasonable effort, including court ordered restitution, to obtain recovery of the losses from the offender.

Procedures for Reporting

All Employees:  Any employee who has knowledge of an occurrence of fraudulent conduct, or has reason to suspect that a fraud has occurred, shall immediately notify the Executive Director.  If the employee has reason to believe that the Executive Director may be involved, the employee shall immediately notify the Chairman of the Finance Committee.

Executive Director:  Upon notification from an employee of suspected fraud, or if the Executive Director has reason to suspect that a fraud has occurred, he/she shall immediately notify the Chairman of the Finance Committee or Chairman of the Board of Directors.

Board Director:  If a member of the Board of Directors suspects fraud, he/she shall notify, at his/her discretion, the Executive Director or the Chairman of the Finance Committee.

Investigation

Upon notification or discovery of a suspected fraud, the Executive Director, in concert with the Finance Committee, will promptly investigate the fraud.  Every effort will be made to keep the investigation confidential.

After an initial review and a determination that the suspected fraud warrants additional investigation, the Executive Director and Finance Committee will notify the Executive Committee of the Board as appropriate. When deemed necessary, the Executive Director shall coordinate the investigation with the appropriate law enforcement officials.  Internal or external counsel will be involved in the process, as deemed appropriate.

It should be noted that there may be certain instances of fraud that will be handled in the normal course of business that will not result in a separate "investigation" by the Finance Committee.

Security of Evidence

Once a suspected fraud is reported, immediate action 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.  The records must be adequately secured until the Executive Director/Finance Committee obtains the records to begin the audit investigation.

Confidentiality

All participants in a fraud investigation shall keep the details and results of the investigation confidential.

Personnel Actions

If a suspicion of fraud is substantiated by the investigation, disciplinary action, up to and including dismissal, shall be taken by management.

Whistle-Blower Protection

No employee of the Organization, or person acting on behalf of the Organization 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 penalized 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.  If, however, individuals make malicious allegations, action may be considered against the individual making the allegation.