Safe Disclosure

Safe disclosure is ONE component of Western’s overall ethics environment, and it contributes to a system of strong ethical culture and psychological safety, by providing a supplemental mechanism to report concerns, of improper financial activity or unethical behaviour, while protecting employees who report these concerns.

First you should pause to acknowledge what you are experiencing or witnessing. Record the details and gather additional information. Consider pursing a conversation to understand the situation more if safe to do so. It can be difficult to determine whether the incident is inappropriate so do not investigate the matter yourself or accuse anyone you suspect directly. You should report the incident in a timely manner through the appropriate reporting office or process.

Western depends on its members to raise workplace concerns so the University can learn about issues that put its people, finances, and reputation at risk. By voicing workplace concerns you contribute to improving Western’s performance, protecting our reputation, and reducing the impact of incidents or avoiding them altogether.

Members of the University community can make a safe disclosure. The University community includes employees, students, volunteers, and other individuals who work, study or engage in activities at the University.

Internal Audit is the point of contact for safe disclosures. Internal Audit reports functionally to the Audit Committee of the Board of Governor’s which provides Internal Audit independence from management. Internal Audit has no operational responsibilities which allows them to investigate safe disclosures objectively without influence or bias.

In support of the Safe Disclosure policy, Internal Audit fully welcomes unethical workplace concerns. We believe in a psychological safe and inclusive Western and that no one should be punished or humiliated for speaking up. We also believe that when we are courageous in speaking up, we have a bold impact on the Western Experience for everyone.

Collect and report as much information as possible to answer these questions: What is happening; Who is involved; When did it occur and where; Estimated $ value; The policy or law breached; Evidence and any other relevant details.

Once you confirm the questionable unethical activity is not covered under an existing office or policy, then you have 3 options to report through the safe disclosure process based on your comfort level:

(1) your immediate supervisor and Internal Audit,

(2) one level above your supervisor and Internal Audit, or

(3) directly to Internal Audit.

You can use the "Report a Concern" link above, or reach out to the Director of Internal Audit via In person; Email; Phone; or Mail. Provide your contact information unless you desire anonymity, but keep in mind that a thorough investigation can be inhibited with anonymous reports.

You will receive an acknowledgment that your concern was received and be provided with an overview of the process. Internal Audit evaluates the disclosure to determine if (1) investigation is possible/required and (2) if a matter more properly falls within a different University procedure. Based on this evaluation, an investigation may be undertaken through the appropriate process.

Investigation processes as defined in Western policies or employee agreements are followed. Investigators gather evidence (such as what happened, what normally happens, policy/legal requirements, why it happened) and conduct applicable interviews to justly evaluate the questionable activity. Findings and any recommendations are produced (including behaviour choices and organizational system design) and reported in accordance with policy.

Your safe disclosure is kept confidential and only shared with those personnel associated with the University who have a need to know such details and results in order to perform their duties and responsibilities.

Internal Audit is involved in a safe disclosure investigation unless the investigation falls within a different University procedure or is better performed through other investigators with subject matter expertise.

Each investigation is handled based on its unique circumstances and therefore an exact timeline is not provided. Internal Audit is committed to undertaking an investigation as timely as possible. The disclosing individual will receive periodic status updates.

At the end of an investigation Internal Audit moves into the reporting stage. The disclosing individual will be informed that the investigation is complete. Findings are communicated to the President or appropriate VP. Improper financial activity findings are communicated to VP (Operations & Finance). In cases where the investigation concluded that unethical behaviour or improper activity has occurred, then the Audit Committee of the Board of Governors is informed. Where the investigation has concluded that unethical behaviour or improper financial activity has not occurred, the Audit Committee will receive an aggregate summary of allegations.

In order to conduct an objective investigation, free of influence, the investigation follows an independent process. Therefore, it is important for you to provide as much information as possible in your safe disclosure. Internal Audit may also request additional information from you during the investigation.

Safe disclosure is meant to supplement, not replace, other reporting offices and policies in place at Western. If the incident relates to improper financial activity, unethical activity not covered elsewhere, or if the disclosing individual is not comfortable using other reporting processes, then safe disclosure is the mechanism to use. For improper financial activity Internal Audit should always be notified.

The safe disclosure process exists to protect you from retaliation and harassment of any kind. Anyone experiencing retaliation should immediately inform Internal Audit, who in turn, must contact the appropriate human resource officer.

There are support and resources available to you both within Western and in the community. Western Human Resources website includes information to the Employee Assistance Program, community resources, and other support for your wellbeing

Western HR - Mental Health

Mental Health Resources for Western Staff & Faculty

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 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