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Safe Disclosure Procedure

 

I.    Disclosure

  1. This Procedure outlines a process for receiving disclosures of, and investigating, suspected fraud, theft and misappropriation of University resources.

  2. The University encourages members of the community who become aware of suspected fraud, theft or misappropriation of the University’s resources, to make a timely disclosure in accordance with this Procedure.

  3. A disclosure can be made in person, by email, by mail, or by telephone to any of the following:  chief internal auditor; chief financial officer; chief human resources officer; or general counsel.  Contact information for those individuals is provided in Appendix A.

  4. A disclosure can also be made using the Safe Disclosure Reporting Form located on the University’s website for internal audit services.  The chief internal auditor shall review every safe disclosure reporting form submitted.

II.   Confidentiality

  1. An individual making a disclosure is encouraged to self-identify to enable the University to investigate the allegation most effectively.  If an individual is uncomfortable with self-identification, disclosure will still be accepted.

  2. A disclosure should include, if possible, a description of the nature of the suspected activity, relevant dates, name of each individual involved in the activity, and any additional information or documentation that would assist in conducting an investigation into the suspected activity.

  3. Notwithstanding the request for full disclosure of as much information as possible, an individual making any disclosure should not take any steps in an attempt to investigate, confirm, or in any way verify or validate the suspected activity.

  4. Recipients of a disclosure of suspected wrongdoing shall treat the information and the identity of the discloser as confidentially as possible throughout the process.

  5. The University shall protect the confidentiality of an individual identified in any disclosure made under this Procedure as being suspected of improper activity except as may be required by law or to conduct an investigation into the suspected activity.

III.  Protection of a Party Making a Disclosure

  1. The University shall take reasonable steps to ensure that an individual who in good faith and in accordance with this Procedure makes a disclosure of suspected wrongdoing is protected from reprisals in employment as a consequence of such disclosure, including but not limited to dismissal or threat of dismissal, discipline, suspension, docking of pay or threat thereof, harassment or intimidation in the workplace.

  2. An individual who experiences such reprisal or threat as a result of disclosure in accordance with this Procedure shall inform the chief human resources officer who shall investigate the matter and take appropriate action.

  3. Disciplinary action may be taken against any individual who is found to have retaliated against an individual who has disclosed, in good faith, suspected improper activity.  Such disciplinary action may include termination of employment, contract, or other relationship with the University.

  4. An individual who knowingly makes a false or malicious allegation may be subject to disciplinary action.

IV.  Investigation Process and Reporting Results

  1. The chief internal auditor shall conduct a preliminary investigation into an allegation of fraud, theft, or misappropriation.

  2. If the chief internal auditor determines that there is sufficient evidence or reasonable grounds to pursue an allegation and that there is a possibility of wrongdoing such that an investigation is warranted, the chief internal auditor shall, in collaboration with the chief human resources officer; chief financial officer; and general counsel, conduct an investigation of all substantive allegations of fraud, theft, or misappropriation.

  3. Investigations are conducted in confidence and in accordance with any applicable legislation or applicable collective agreement.

  4. The University shall provide the investigator with access to all relevant premises and records, and employees are expected to provide full cooperation with the investigator, subject to any legal rights including those under relevant collective agreements.

  5. The chief internal auditor shall communicate the findings of any investigation to appropriate officers of the University, the Audit Committee of the Board of Governors, and the external auditor, and shall inform the individual who made the disclosure, if known, that the investigation has been completed.

    Safe Disclosure Procedure – Appendix A

Disclosure can be made in person, by email, by mail, or by telephone to any of the following: 

Brian Reny 

Chief Internal Auditor

cia.safedisclosure@torontomu.ca

 

Joanne McKee

Chief Financial Officer

cfo.safedisclosure@torontomu.ca

 

Jenny O'Donnell

Chief Human Resources Officer

chro.safedisclosure@torontomu.ca

 

Wendy Lawrence

General Counsel and Secretary of the Board of Governors, and Chief Privacy Officer

gc.safedisclosure@torontomu.ca