Reviewed by President and Vice-Presidents: June 16, 2010. Effective: June 21, 2010
Approval Authority: Vice-President Finance and Administration
Signature: Gary Brewer
Description: Procedure to deal with acts of non-academic fraud that occur at the University by employees, agents, contractors and volunteers. Also sets out reporting process and articulates the University’s commitment to protect employees who disclose concerns about unethical conduct and fraudulent behaviour that they observe or encounter in the context of University activities. Has associated policy.
Procedure: Disclosure of Evidence of Fraud, Theft or Misappropriation of University Assets
This procedure establishes a process for reporting and investigating evidence of fraud, theft and misappropriation of University assets by University employees, agents, contractors and volunteers. It is not intended to apply to issues of academic misconduct or fraudulent actions by students acting solely in their capacity as students, nor to misconduct in academic research, each of which have separate procedures.
- Persons who encounter evidence of fraud, theft or misappropriation of University assets shall make a timely disclosure of such evidence in accordance with these procedures to one of the following persons: the Assistant Vice-President Finance & Chief Financial Officer, the Assistant Vice-President Human Resources and Employee Relations, the Director of Internal Audit; the Director of the Centre for Human Rights; the University Secretary and General Counsel.
- While the University will take such steps as are possible to protect the identity of persons making disclosure, information provided, including the identification of these individuals, may be disclosed if necessary for the University to take disciplinary or other action.
- In order to proceed, the University may require the disclosure to be evidenced in writing, signed and accompanied by any documentation in support of the allegation.
III. Protection of a Party Making a Disclosure:
- The University will take all reasonable steps to ensure that persons who in good faith and in accordance with this procedure disclose evidence of wrongdoing will be protected from reprisals in their employment as a consequence of such disclosure including: dismissal or threat of dismissal, discipline, suspension, docking of pay or threat thereof, harassment or intimidation in the workplace.
- Any person who experiences such reprisals or threats as a result of disclosure in accordance with this procedure shall inform the Assistant Vice-President, Human Resources and Employee Relations who shall ensure the matter is investigated and appropriate action taken.
IV. Investigation of Allegations of Fraud, Theft and Misappropriation:
- When the University receives evidence of fraud, theft or misappropriation, it shall appoint one senior official, normally the Director of Internal Audit, to oversee the coordination of an investigation of the evidence.
- Investigations will be conducted with an appropriate level of confidentiality, and with respect for the requirements of any legislation or applicable collective agreements.
- The investigator(s) shall have access to all relevant University premises and records, and employees are expected to provide full cooperation with the investigator, subject only to legal rights including those under relevant collective agreements.
- The results of any investigations will be reflected in a written report which shall be issued to senior University officers and, in the normal course (and in any event when the allegations have been substantiated), to the Finance and Audit Committee of the Board of Governors.