U of R Home
Policy
Browse
GOV-022-020 Safe Disclosure

University of Regina Policy

Safe Disclosure

Category:Governance

Number:GOV-022-020

Audience:All University members

Issued:December 10, 2013

Revised:April 28, 2026

Owner(s):Chief Governance Officer

Approved by:Board of Governors

Contact:Internal Auditor 306-337-3127 safe.disclosure@uregina.ca

Introduction

This policy applies to the following members of the University:

students,
employees (faculty, staff, student employees),
all people who teach and conduct research at the University of Regina, and
all members of University committees (including the Senate and Board of Governors), and
University volunteers, consultants, contractors, to the extent that University resources and personnel are involved or impacted.

The University is committed to upholding standards of conduct that reflect respect, integrity, and honesty in its day-to-day decisions, actions, and interactions. The University is also committed to protecting its revenue, property, information, and other assets and will immediately act on any reported violations of the law or University policy.

The purpose of this policy is:

to offer University members a mechanism for reporting good faith allegations of financial wrongdoing (such allegations are sometimes referred to as “whistleblower” reports), where no other process exists under an alternate policy;
to prescribe procedures for the reporting, investigation, and response to good faith allegations; and
to protect those who make good faith allegations by prohibiting subsequent retaliation against them.

Investigations will only be undertaken under this policy when other means to address the allegation are exhausted, unavailable, or unacceptable at the University’s discretion.

This policy is not intended to limit, amend or replace an existing policy or agreement that has been established for purposes including but not limited to:

individual complaints, appeals, grievances, management of employee performance or disputes over provisions in a collective agreement;
discrimination, workplace violence or harassment, sexual violence, health and safety or human rights; or
appeals, complaints, grievances or issues associated with academic misconduct, research, and intellectual property.

Situations where there is an imminent threat to University property must be reported immediately to Protective Services 306-585-4999.

Definitions

Policy

Any member who has reasonable grounds to believe that another member has committed financial wrongdoing shall report the allegation to the Office of Internal Audit.

While written disclosures are strongly encouraged, disclosures may also be made verbally. In case of a verbal disclosure, the Office of Internal Audit may request that the reporter confirm the information in writing to support further assessment or investigation. A Safe Disclosure Report template (259 KB) is available.

The report may be anonymous; however, a reporter's decision to remain anonymous may impact the ability of the University to address the allegation.

The Internal Auditor will objectively and independently consider all reported allegations. Allegations will be considered regardless of the accused’s position, title, and length of service or relationship with the University.

The Internal Auditor will decide if and how an investigation shall proceed. An investigation may be performed by the Office of Internal Audit or by another investigator or an investigation team, if required.

Members of the University community, including the accused and the reporter (if known), are expected to cooperate fully with the investigator (or investigation team) to ensure that any suspected financial wrongdoing is investigated thoroughly.

Members are not to take it upon themselves to investigate a suspected financial wrongdoing, and they should not discuss a financial wrongdoing or allegation they have reported with anyone other than as authorized by the University.

All information about the allegation and the investigation will be shared only with those who have a legitimate need to know. Consistent with the principle of an individual being innocent until proven guilty, all reasonable steps will be taken to protect the identity (if known) of the reporter and the accused.

Roles and Responsibilities

University Members

must not participate in or tolerate any financial wrongdoing; and must consistently promote and demonstrate professional conduct, ethical behavior, and integrity through compliance with all applicable university policies and procedures, laws, rules, and regulations.
who are aware of or reasonably suspect financial wrongdoing shall report the activity to the Office of Internal Audit.
who believe that they have been subject to retaliation as a result of reporting an alleged financial wrongdoing under this policy should immediately report any kind of retaliation to the Office of Internal Audit.
shall cooperate with the investigator or investigation team and respond in a timely fashion to any request for information or meetings if an investigation of an alleged financial wrongdoing is undertaken.

Board of Governors

oversees the safe disclosure reporting of allegations of financial wrongdoing through its Audit & Risk Management Committee by reviewing reports from the Office of Internal Audit on allegations received, investigations performed, results of investigations, and actions pursuant to the investigations.
through its Audit & Risk Management Committee, ensures that senior management provides the investigator with the resources and support necessary to conduct thorough investigations.

Senior Executive

establishes effective controls and procedures in order to prevent and detect fraud, and to safeguard University assets and resources.
ensures that the University has appropriate and effective procedures for dealing with allegations of financial wrongdoing.
ensures that this policy and related procedures are communicated to University members.
monitors compliance with this policy and related procedures.

Chief Governance Officer

reviews the results of investigations of alleged financial wrongdoing.

Office of Internal Audit

acts as a central point of contact for receiving disclosures of an alleged financial wrongdoing.
has the primary responsibility for coordinating investigations of allegations of financial wrongdoing.
prepares the investigation findings for communication to appropriate Senior Executives and the Audit & Risk Management Committee.
prepares semi-annual reports to the Audit & Risk Management Committee on allegations received, investigations performed, results of investigations, and actions pursuant to the investigations.
shall treat all information that it collects or receives in confidence except as is necessary for a thorough investigation and/or as required by law or a standard of ethical conduct.

Processes

Reporting an Allegation of Financial Wrongdoing

1. A member reports his or her or their suspicions or knowledge of a financial wrongdoing to the Office of Internal Audit. An allegation should be brought in a timely manner and include clear and detailed information about the financial wrongdoing, including places and dates, person(s) involved, witnesses, and evidence available(if known) so that a reasonable investigation can be conducted. Delay in reporting may affect the University's ability to address the allegation.

2. After receiving the report, the Internal Auditor shall review it and decide if an investigation is warranted. Legal counsel or others may be consulted to assist in this determination.

3. If the Internal Auditor determines that an investigation is warranted, the Internal Auditor may conduct the investigation, or recommend that the Senior Executive appoint a different investigator.

4. If an investigation is warranted, the allegation is also reported to the Chair of the Audit and Risk Management Committee.

5. If the Internal Auditor determines that the allegation is without substance or merit, or it is a malicious allegation, the allegation may be dismissed without investigation. In such instances, the reporter will be so informed, and (other than in the case of a malicious allegation) may be given opportunity to re-submit the allegation with additional evidence.

Investigating Allegations of Financial Wrongdoing

1. The investigator will do an initial assessment and determine if an investigation team is necessary. If necessary, the investigator will contact the University officers and others (i.e. legal counsel, forensic or IT experts) with the required expertise, or an external investigation team may be contracted to perform some or all of the investigation.

2. The Board of Governors, through its Audit & Risk Management Committee, ensures that senior management provides the investigator with the resources and support necessary to conduct a thorough investigation.

3. The investigator coordinates the investigation, consulting with legal counsel and others (if/as necessary). The investigation timeframe will depend on the situation and the complexity of the allegation. Once an investigation begins, all inquiries about the allegation should be directed to the investigator.

4. The investigator reports the investigation procedures, findings, conclusions, and recommendations to the Chief Governance Officer, or to the Chair of the Audit and Risk Management Committee if the allegation or findings involve any of the Senior Executives, and to the Office of Internal Audit if the investigation is not performed by this office.

5. All members, including the reporter, the accused and their advisors, shall fully cooperate with the investigator and provide the information required for the investigation.

6. To maintain the integrity of an investigation process, the University will take reasonable steps to maintain confidentiality to the extent possible during the investigation. Confidentiality may not be possible where identification is required to conduct a thorough and procedurally fair investigation, or to comply with the law.

7. The Office of Internal Audit files all electronic and hardcopy files and documents related to the investigation according to the established record retention and archiving schedule.

Reporting the Allegations and Results of Investigations

1. The results of investigations will be promptly reported to the Chief Governance Officer and the Chair of the Audit & Risk Management Committee and also to the Audit & Risk Management Committee at least semi-annually.

2. Where the report confirms that the accused has committed financial wrongdoing, sanctions or disciplinary measures will be taken as deemed appropriate, as well as possible legal action.

3. The University may contact the University’s insurer, the Provincial Auditor, and law enforcement agencies (if appropriate).

4. The Internal Auditor will provide semi-annual reports to the Audit & Risk Management Committee on allegations received, investigations performed, and actions taken pursuant to the investigations.

5. All reports prepared by the Internal Auditor are intended to be confidential.

Protection from Retailiation for Reporting Financial Wrongdoing

1. It is contrary to this policy for anyone to retaliate, engage in reprisals or threaten to retaliate against any person for: - having made an allegation under this policy; - having participated or cooperated in an investigation under this policy; or - having been associated with someone who has pursued rights under this policy. Anyone engaged in retaliatory conduct may be subject to sanctions and/or discipline.

2. Any member experiencing retaliatory conduct should immediately report it to the Internal Auditor (or Protective Services if there is an imminent concern or threat to a person’s safety).