**145.1 PURPOSE** To inform all employees and their supervisors of their
obligations to report any incidents of fraud of which they may have
knowledge; to establish procedures for such reporting; to outline
responsibility for the investigation of any allegations; and to
establish guidelines for any action that should be taken against
employees involved in any fraudulent activities.

**145.3 DEFINITION** For the purpose of this manual, **fraud** is
defined as deceiving or taking advantage of the U.S. Government, either
directly or through its contractors, and usually, but not necessarily,
for personal gain. Fraud may include, but is not limited to,
embezzlement, larceny (theft), bribery, forgery, making false claims or
false statements, and collusion and/or conspiracy between two or more
persons to defraud. Examples of fraud may include, but are not limited
to

> **A. Misuse of purchasing/requisition authority;**
>
> **B. Falsification of official Government records** such as time and
> attendance reports, inventories, and travel vouchers;
>
> **C. Stealing Government property;**
>
> **D. Misuse of Government vehicles, aircraft, computers, tools, and
> equipment;**
>
> **E. Misuse of Government credit cards; and**
>
> **F. Abuse of mailing privileges**.

**145.4 POLICY**

> **A. All BPA employees have a responsibility to promptly report** any
> known or suspected fraudulent activity to BPA\'s Manager, Internal
> Audit or the DOE Office of the Inspector General (OIG). When the
> activity involves theft of BPA equipment, materials, or documents,
> employees should also report it to BPA\'s Security Manager. All
> allegations will be expeditiously and confidentially investigated in
> order to determine the evidence of possible wrongdoing. Employees who
> are found to have committed fraud shall be subject to administrative
> action in accordance with Federal, DOE, and BPA personnel regulations.
>
> **B. It is BPA policy to initiate appropriate administrative action**
> against an employee, up to and including removal from the Federal
> service, when the evidence establishes that the employee has taken
> advantage of the U.S. Government.

**145.5 RESPONSIBILITIES**

> **A. Any employee who has knowledge of or suspects that fraud is being
> or has been committed** against the U.S. Government shall contact, as
> promptly as possible, BPA\'s Internal Audit Manager or the
> representative of the OIG and report all facts concerning the
> potential fraud incident. Employees shall *not* attempt to investigate
> a potential fraud incident, as such action may subsequently jeopardize
> the outcome of a formal investigation conducted by trained
> investigators. All employees shall cooperate fully with the Internal
> Audit Manager and the OIG during all phases of an investigation.
>
> **B. The Security Manager or Security Management staff** will promptly
> notify the Internal Audit Manager and/or OIG upon the receipt of any
> information concerning potential fraud.
>
> **C. Upon receipt of information concerning potential fraud**, the
> Internal Audit Manager will promptly consult with the OIG and, as
> appropriate, initiate a preliminary inquiry in order to determine the
> probability of fraudulent activity. During the preliminary
> investigation, there will be close contact between the Internal Audit
> Manager and OIG, and as appropriate, between the Internal Audit
> Manager and the Security Manager and/or other BPA managers involved.
> When it appears likely that fraud has been committed, the Internal
> Audit Manager will formally refer the case to the OIG for further
> investigation. The Internal Audit Manager will serve as the
> Administrator\'s point of contact with OIG, and will keep the
> Administrator, appropriate managers, General Counsel and Employee
> Relations fully informed of the status of each investigation.
>
> **D. The BPA Managers involved** are responsible for evaluating all
> findings conveyed through the Internal Audit Manager, either during or
> after a preliminary inquiry or investigation, and for initiating
> appropriate personnel actions. Consultation with the Internal Audit
> Manager, Human Resources, and the General Counsel is appropriate to
> assure accuracy of facts upon which administrative action is based;
> compliance with Federal Government, DOE, and BPA rules and
> regulations; proper legal interpretation of the charges and action
> proposed; and consistency of administrative action on a case-by-case
> basis across BPA organizational lines.

**145.6** **STATUS OF EMPLOYEE DURING PRELIMINARY INQUIRY:** Evidence
uncovered during a preliminary inquiry by the Internal Audit Manager
which indicates suspicion of one or more employees will be presented to
the **employee\'s** **manager** for consideration of administrative
actions

**145.7 STATUS OF THE EMPLOYEE AFTER THE INVESTIGATION:** Upon
conclusion of the OIG investigation, the appropriate administrative
action shall be consistent with Personnel Letter 752-1, Discipline,
Adverse Actions and Alternative Discipline. This action may range from
an oral admonishment to removal from the Federal service.

**145.8 RECORDS RETENTION:** The BPA preliminary inquiry files and
information pertaining to any subsequent OIG investigation which the OIG
makes available to BPA shall be retained by the Internal Audit Manager.
When adverse action is proposed, copies of the pertinent parts of these
files necessary to support that action will be made available to **be
included in** the adverse action file.

**145.2 REFERENCES**

> **A. 5 CFR Part 752, Adverse Actions by Agencies.**
>
> **B. Order 470.1, Safeguards and Security Program. Unclear whether
> this still applies. Could not find any references pertaining to Order
> 470.1**
>
> **C. Personnel Letter 752-1, Discipline, Adverse Actions and
> Alternative Discipline.**

D.  **BPA Manual Chapter 400/792A, (Use of Alchol and Substance Abuse on
    BPA Property)**

E.  **BPA Manual Chapter 400/792C, Drug Free Workplace**

F.  **BPA Manual Chapter 1073, Firearms and Other Weapons**

G.  **10 CFR Section 1010.106 -- Responding to Wrongdoing**

H.  **10 CFR Section 1010.109 -- Cooperation with I.G.**

I.  **5 CFR Section 2635 -- Standards of Ethical Conduct**

> **J. BPA Manual Chapter 1070, Security Management.**