Over the past few years there has been a growing trend in the private and public sector to implement polices where members of organizations can report any knowledge 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 effort to support high standards of honesty and integrity, The University of Western Ontario has implemented a Safe Disclosure Policy effective September 25th, 2007, that allows its members to express concerns of unethical behaviour or improper financial activity without the fear of retaliation. The policy supplements the existing comprehensive university processes that deal with various acts of misconduct.
The Safe Disclosure Policy administered by the University’s Internal Audit Department will handle concerns of unethical behaviour or financial wrongdoing. Information relating to the 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.
The Safe Disclosure Policy can be found at: http://www.uwo.ca/univsec/mapp/section1/mapp143.pdf . If you have questions regarding the policy, contact the Internal Audit Department at (519)661-2111 ext. 85435.
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.
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 ( http://www.uwo.ca/police/ ) should be contacted where an individual is aware 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 http://www.uwo.ca/univsec/mapp/section1/mapp135.pdf or through provisions in the relevant collective agreement.
- In cases of suspected academic dishonesty, matters should be reported in accordance with Policy 7.0 http://www.uwo.ca/univsec/mapp/section7/mapp70.pdf , Policy and Procedures for the Conduct of Research. Faculty members suspected of a faculty conflict of interest should use the provisions provided in the Faculty Collective Agreement.
- 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.
If a person’s concern is not addressed by these processes then they should contact their immediate supervisor and the Internal Audit Department as soon as possible after becoming aware of the possible improper financial activity. If for some reason, the employee does not feel comfortable communicating concerns to his/her immediate supervisor, the employee should notify the person one level above the immediate supervisor. If this route is also uncomfortable for any reason, the employee should contact the Internal Audit Department directly.
Can I make an anonymous complaint?
In order that a complaint can be properly evaluated and a proper investigation be conducted (if required), it is not recommended that a member submit an anonymous concern. It is important that all relevant details be acquired and a follow-up can be arranged if required and as such it is recommended that the person contact the Internal Audit department by telephone or in another manner that will allow follow-up. The individual coming forward with a concern will have their confidentiality protected as outlined in the Safe Disclosure Policy.
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.