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Procedures for Safe Disclosure Policy (5.14)

Procedures for Safe Disclosure Policy (5.14)

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This online version is for convenience; the official version of this policy is housed in the University Secretariat. In case of discrepancy between the online version and the official version held by the Secretariat, the official version shall prevail.

Approving Authority: Board of Governors

Original Approval Date: June 23, 2011

Date of Most Recent Review/Revision: November 14, 2024

Administrative Responsibility: University Secretariat

Parent Policy: 5.14 Safe Disclosure Policy

These procedures set out the process and guidelines to facilitate the safe disclosure and investigation of Wrongdoing under Policy (5.14).

1.00 Definitions

1.1 Good Faith Disclosure (Disclosure): any disclosure made under this Policy concerning an actual or perceived Wrongdoing that is based on reasonable belief and is not malicious, frivolous, vexatious or made in bad faith.

1.2 Respondent(s): the individuals against whom an allegation of Wrongdoing is made

2.00 Disclosure

2.1 In accordance with the Safe Disclosure Policy, anyone who has information and reasonable grounds to believe there has been Wrongdoing by a Member of the University Community pertaining to University business that is not addressed by other policies/procedures, is encouraged to make a Good Faith Disclosure to persons in authority at the University.

2.2 Disclosures of Wrongdoing should be made in a timely manner and generally within thirty (30) days of discovering the Wrongdoing.

2.3 Disclosures must be made in writing and signed and should include as much detail as possible, including:

a. the nature of the Wrongdoing being reported;

b. when and where the Wrongdoing occurred or may occur;

c. names of all parties involved and their role in the Wrongdoing;

d. names of anyone else who knows about the Wrongdoing;

e. steps taken to report the activity, if applicable;

f. if the Wrongdoing reported involves a financial loss, an estimate of the amount involved;

g. identification of any policies, laws or regulations believed to have been breached; and

h. copies of any documents or other materials available to support the Disclosure.

2.4 An individual making a disclosure should not take any steps to investigate, confirm, or in any way verify or validate the suspected activity and should not discuss a wrongdoing or allegation they have reported with anyone other than as authorized by the University.

3.00 Investigation

3.1 The supervisor or manager to whom a Disclosure is made shall notify the AVP, Governance & Policy, in accordance with the Safe Disclosure Policy. If a Disclosure is against AVP, Governance & Policy, the supervisor or manager to whom a Disclosure is made shall notify the General Counsel and Chief Legal Officer.

3.2 The AVP, Governance & Policy, or designate, shall consider whether the Disclosure is within the scope of this Policy or another University policy, procedure or process and may be more appropriately addressed through another University process or department (e.g., those on harassment, or academic misconduct).

3.3 Where the disclosure is confirmed by the AVP, Governance & Policy, or designate to be within the scope of the Safe Disclosure Policy, the Disclosure will be investigated carefully and fairly, respecting privacy and confidentiality as appropriate. If the disclosure is determined to lack reasonable grounds to investigate or to have not been made in good faith, the AVP, Governance & Policy or designate may decline to investigate further and will notify the discloser of this decision. This will be reported to the Audit, Risk and Compliance Committee of the Board of Governors at their next meeting.

3.4 The AVP, Governance & Policy, or designate, shall have access to internal or external audit or legal counsel, and such other advisors as deemed necessary to complete the investigation.

3.5 The AVP, Governance & Policy, or designate, is entitled to require the person(s) who have made the Disclosure to meet with them to discuss the allegation and provide all available information supporting the allegation. In investigating the Disclosure, the AVP, Governance & Policy, or designate, is entitled to request a confidential meeting with any Member of the University Community who may have relevant knowledge of the matter.

3.6 In all investigations, the Respondent(s) shall be given a summary of the information gathered in the investigation and a reasonable opportunity to provide a written response to the alleged conduct or complaint and the opportunity, if requested, to meet with the investigator.

3.7 The AVP, Governance & Policy, or designate, shall deliberate carefully and determine if Wrongdoing has occurred and submit a written report to the University President (or Chair, Board of Governors for a Disclosure against the University President) outlining their findings and recommendations. Where there is a finding of Wrongdoing, they shall also provide a copy of the decision to the appropriate internal supervisor or manager to address mitigation. The Chief Human Resources and Equity Officer (or their designate) shall be notified and receive a copy of the report if discipline arising from a determination of Wrongdoing is recommended.

3.8 The University will provide to the Respondent(s) written notice of the finding of the investigation. The Respondent(s) will have seven (7) working days following the date of this notice to provide a written response.

3.9 To maintain confidentiality, the results of individual investigations will be reported only to those parties with a need to know as determined by the President (or Chair of the Board of Governors, as noted above).

3.10 All individuals involved in the disclosure, allegation, or an investigation, including any individual(s) who disclosed the matter, shall keep the details, and results confidential, to the extent possible within the limitations of the law, collective agreements, and University policies.

4.00 Reporting

4.1 The AVP, Governance & Policy, or designate, shall prepare an annual report to the Audit, Risk & Compliance Committee of the University Board of Governors which will include a summary of the number, nature and disposition of all investigations made under this policy. This report, together with any recommendations, will be provided to the Board of Governors, normally at its annual meeting.

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