Conflict of Interest Investigation

Our role was to quantify the total purchases made from this business, determine whether the employee had reported this conflict of interest to the municipality, if the conflict of interest policy had been violated, identify any possible fraud schemes that may have been carried out by the employee, and identify other vendors owned or controlled by the employee from whom the municipality purchased goods or services.

We examined the conflict of interest policy and the employee’s personnel file to understand how conflicts were defined by the municipality, and whether the employee had reported any conflicts. We examined various bids arranged by the employee for the purchase of goods and services to determine whether the bids were awarded correctly, or if there was evidence of kickbacks or bid rigging. We interviewed the Chief Financial Officer of the municipality to understand the procedures required to be followed for the setup of new vendors and the approval of invoices.  MDD also examined the municipality’s vendor database, and identified suspicious vendors requiring further investigation (which involved analyzing corporate search reports to identify the directors and owners of the businesses).