Over the past few years there has been a trend in the private and public sector to implement polices where members of organizations can report their concerns of improper financial activities. High profile cases such as Enron have shown the importance of providing a process to allow members of organizations to voice their concerns without an adverse affect on themselves.
In an effort to support this, The University of Western Ontario has implemented a Safe Disclosure Policy, that allows its members to express concerns of improper financial activity or concerns of violations of laws or Western's policies. The policy supplements the existing comprehensive university processes that deal with various acts of misconduct.
The Safe Disclosure Policy can be found at: http://www.uwo.ca/univsec/mapp/section1/mapp143.pdf.
Information relating to a concern will be evaluated by Internal Audit to determine if an investigation is required. The individual reporting the issue may be contacted to obtain additional information to help complete this investigation. Information received by Internal Audit will be treated as confidential within the limitations of the law, collective or employee agreements and University policies.
If you have questions regarding the policy, contact the Internal Audit Department at (519) 661-2111 ext. 85435.
Frequently Asked Questions:
What should I do if I have a concern relating to misconduct at the University?
The University has established a number of processes to deal with various acts of misconduct:
- The Campus Community Police should be contacted where an individual has reason to believe that a possible criminal offence has occurred.
- Issues that involve discrimination and harassment should be referred to the Equity and Human Rights Office through Policy 1.35 or through provisions in the relevant collective agreement.
- In cases of suspected academic dishonesty, matters should be reported in accordance with the appropriate policy: Academic Integrity in Research Activities, Senate Policy on Scholastic Discipline for Undergraduate Students, or Senate Policy on Scholastic Discipline for Graduate Students.
- In the case of an alleged faculty conflict of interest, the provisions in the Faculty Collective Agreement or the Conditions of Appointment for Physicians should be followed.
- Individuals with concerns about unethical behaviour that may be addressed through provisions of a collective agreement or other employment agreement governing their relationship with the University should follow the process identified by the relevant agreement
For any other concerns, individuals should contact their immediate supervisor and the Internal Audit Department in a timely manner after becoming aware of the behaviour or activity. If an employee does not feel comfortable communicating concerns to his/her immediate supervisor, the employee should notify the person one level above the immediate supervisor and the Internal Audit Department. If this route is also uncomfortable, the employee should contact the Internal Audit Department directly.
What if I bring forward a concern and feel I have been adversely affected at work?
The Safe Disclosure Policy ensures that as long as an individual comes forward in good faith with a concern they will not be retaliated against. If a person feels they are being adversely affected because they have come forward then the person should contact the person to whom the original report was made. This person must then contact the appropriate human resource officer.
The Safe Disclosure policy refers to the concept of "Good Faith" when making a disclosure. Below are some examples and a definition of Good Faith.
Good Faith Definition and Examples:
Good Faith can be defined as an act done with honesty and without knowledge of fraudulent circumstances or intent to misrepresent.
Some examples of disclosures made in good faith would include:
- A disclosure where a member of the University has witnessed another member of the University processing transactions which they have not been given authorization to do so or processing them in a manner inconsistent with policies or procedures.
- A disclosure that a member of the University has identified or witnessed payments to an employee or a business not related to the dealings of the University or unit.
- A disclosure regarding a member of the University approached by another member of the University and asked to perform an act contrary to law or the policies and procedures of the University.
- A member of the University discloses that they have specific knowledge of an employee submitting fictitious receipts for reimbursement of travel claims.
Some examples where a person would not be acting in good faith would include:
- The person making the disclosure does so knowing that some or all of the information provided (whether as fact or opinion) is not truthful or has reckless disregard for the truth.
- The person making the disclosure knowingly withholds information related to the situation being disclosed (especially if the information withheld is contrary to the information being provided).
- An employee has heard a rumor regarding another employee and is in a position to easily determine whether or not it is true, but instead reports the rumor through the safe disclosure process.