Reporting Incidents of Suspected Financial Impropriety Procedure

• The University is committed to high standards of financial management across the University in every division and collectively in the University as a whole.
• It expects all employees to follow its various policies regarding financial matters.
• With this commitment and with existing controls and policies when minor financial irregularities occur (and this is inevitable in any very large and complex organization) they can usually be corrected and responded to quickly and appropriately using existing practices.
• Where it is believed that more serious irregularities have occurred or are occurring, special procedures should be available to respond clearly, appropriately, and in a timely and effective manner.
• Employees who have concerns must be confident that they can raise them in a variety of ways, without fear of reprisal.
• To that end, all employees are expected to adhere to this protocol.

Serious Financial Improprieties include, but are not limited to:

1. Forgery or alteration of cheques, drafts, promissory notes and securities.
2. Any misappropriation of funds, securities, supplies or any other asset.
3. Serious irregularity in the handling or reporting of money transactions.
4. Misappropriation of furniture, fixtures and equipment.
5. Seeking or accepting anything of significant value from vendors, consultants or contractors doing business with the University in violation of the University’s Conflict of Interest policy.
6. Any computer related activity involving the alteration, destruction, forgery or manipulation of data for fraudulent purposes or misappropriation of University-owned software.
7. Any claim for reimbursement of expenses that are not incurred for the exclusive benefit of the University.

These procedures do not displace the right of any employee to contact Internal Audit directly to seek advice regarding what he/she believes, in good faith, to be a financial impropriety, (whether serious or not).  Such an inquiry will be handled with sensitivity and in a timely manner and without risk of reprisal.

Similarly, even if an employee’s concern does not involve a Serious Financial Impropriety, he/she should raise it with the immediate supervisor.

Nothing in these procedures displaces any existing Policies or contractual rights and obligations.

1. Any employee who is aware of or suspects an incident of Serious Financial Impropriety is to notify her/his supervisor promptly. The supervisor will assess the situation, and where appropriate will raise the matter with the supervisor at the next level above and/or directly with Internal Audit.
2. If the employee’s concerns involve the employee’s supervisor, the employee should notify the person one level above his/her immediate supervisor and this person would then be responsible for assessing the situation and where appropriate raising the matter with the supervisor at the next level above and/or directly with Internal Audit.
3. The expectation is that unless a straightforward assessment quickly and definitively confirms that the concerns are not well-founded (which the supervisor should always confirm with his/her own supervisor) Internal Audit should always be notified in the case of Serious Financial Impropriety.
4. Upon notification or discovery of a suspected misappropriation, the Director of Internal Audit will log the report and promptly investigate the allegation/incident.
5. The Director of Internal Audit may contact, at any time senior administrators and/or officers of the University where the nature of the allegations is such that the Director believes that others should be made aware.
6. If any employee is contacted by an external organization (e.g. audit firm, police) regarding an external investigation into an alleged Serious Financial Impropriety, the employee should promptly contact the Director of Internal Audit before taking any further steps in response to the contact.

1. Where Internal Audit determines that an investigation should be undertaken, it will be guided by the principles of fairness and timeliness. In most circumstances the investigation will be conducted in a confidential manner, in order to be fair to the interests of those involved and to avoid compromising the integrity of the investigation.
2. Where the initial review indicates a sufficient likelihood that the suspected financial impropriety has occurred and warrants additional investigation, the Director of Internal Audit will notify the Secretary of the Governing Council (the President’s designate), the University Senior Counsel and the Vice-President Human Resources and Equity as well as other University Officers on a need-to-know basis.
3. Where the initial review indicates a sufficient likelihood that the suspected financial impropriety has occurred and warrants additional investigation, the Director of Internal Audit will notify, following notification of the individuals noted in (2), the Chair of the Audit Committee about the results of the initial review while protecting the privacy of the alleged or suspected individual(s) involved.   
4. The Director of Internal Audit shall coordinate the investigation with the appropriate law enforcement or other agency where applicable.
5. During an investigation the status of any employee under investigation will be assessed by the supervisor or other official in consultation with Human Resources (this can, depending on the circumstances, include various forms of leave of absence or suspension).
6. The results of investigations will be reported to the subject of the investigation, to the supervisor, and depending on the circumstances may be communicated to others, including Officers of the University including the Chair of the Audit Committee.
7. Employees found to have engaged in Serious Financial Improprieties may be subject to disciplinary action up to and including termination of employment.
8. Disciplinary action may be taken against anyone who makes vexatious or frivolous or bad faith allegations of wrongdoing about another individual.
9. All of the above is subject to provisions of contracts, collective agreements or policies regarding employment, to the extent applicable.
10. The Director of Internal Audit will report to the Audit Committee twice annually the number of reports of suspected financial impropriety received, investigated and the results thereof.

1. No supervisor or other person acting on behalf of the University shall:
   1. Discipline or dismiss or threaten to discipline or dismiss an employee;
   2. Or impose or threaten to impose any kind of penalty or sanction on an employee; or
   3. Intimidate or coerce an employee to act or to refrain from acting,
      
      because that person, acting bona fide, has filed an allegation of financial impropriety pursuant to this procedure or has sought the enforcement of this procedure or has been a witness in any hearing flowing from this procedure.