Safe Disclosure

Category: Governance
Number: GOV-022-020
Audience: All University employees
Issued: December 10, 2013
Revised:
Owner(s): President and Vice-Chancellor
Approved by: Board of Governors
Contact: Executive Director (University Governance) - 306-585-5545

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).

The University is committed to upholding standards of conduct that reflect accountability, integrity, respect, fairness, and transparency 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.

This policy offers members a mechanism for reporting allegations of wrongdoing and describes how the University will investigate all such reports.

This policy does not replace other University policies and processes that allow members to report allegations of wrongdoing, nor does it replace or modify a supervisor’s responsibility in existing University policies; e.g.:

  • GOV-100-015 – Respectful University,
  • GOV-100-016 – Violence Prevention,
  • OPS-080-005 – Use of University Computer and Network Systems, and
  • RCH-020-005 – Research Integrity.
This policy offers members an avenue for reporting allegations of wrongdoing when other University policies and processes prove ineffective.

Definitions

Policy

Any member who has reasonable grounds to believe that another member has violated the law or a University policy or procedure may report the allegation to:

  • their supervisor
  • the Executive Director (University Governance)
  • the President
  • the Chair of the Board of Governors’ Audit & Risk Management Committee (in the case of the President).

All reports must be in writing, but they may be anonymous.

The University 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 President will decide if and how an investigation shall proceed, including the appointment of an investigator or an investigation team. The President will inform the Chair of the Audit & Risk Management Committee when an allegation is received. 

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

The results of the investigation will be reported to the President or the Chair of the Audit & Risk Management Committee.

If an investigation indicates that fraud might have occurred, the UET and/or the Board of Governors will contact the University’s insurance company, the Provincial Auditor, and the police (if appropriate).

The University will assess on a case by case basis whether to pursue, up to and including using a court-ordered restitution, to recover any losses it incurs as a result of a member’s wrongdoing.

Confidentiality and Protection for Complainants

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

All information about the report and investigation will be shared only with those who have a legitimate need for it. Consistent with the principle of being innocent until proven guilty, all reasonable steps will be taken to protect the identity (if known) of the person who reported the allegation and the person who is suspected of a wrongdoing. 

The University will not tolerate retaliation against anyone who reports an allegation, regardless of the result of the investigation.

Members are asked to immediately report any kind of retaliation to the Executive Director (University Governance) or the Coordinator of Harassment, Discrimination Prevention & Conflict Resolution (Human Resources) or Campus Security (if there is a concern or threat to a person’s safety).

Consequences for Noncompliance

Malicious Reports

An allegation of wrongdoing is a serious matter. Any member who knowingly makes an unsubstantiated or malicious report may be subject to disciplinary action up to and including dismissal.

Where wrongdoing is proven to have occurred, the University will apply remedies consistent with the seriousness of the wrongdoing, up to and including termination of the member’s position with the University and referral to a law enforcement agency.

Processes

Reporting an Allegation of Wrongdoing

  1. A member reports his or her suspicions or knowledge of a violation of the law or a University policy or procedure in writing to:
    • their supervisor
    • the Executive Director (University Governance)  
    • the President
    • the Chair of the Audit & Risk Management Committee (in the case of the President).
      The report should provide clear and detailed information about the wrongdoing, including places, person(s) involved, witnesses, and dates (if known) so that a reasonable investigation can be conducted.
  2. The person who receives the report forwards it to the President
  3. As urgently as possible and not later than 7 business days of the report, the President reviews the complaint and determines if an investigation is warranted.
  4. If an investigation is warranted, the President appoints a lead investigator or investigating team.
  5. If an investigation is warranted, the allegation is reported to the Board of Governors.

Investigating Allegations of Wrongdoing

  1. The lead investigator will do an initial assessment and determine if an investigation team is necessary.  If necessary, an external investigation team will be contracted to perform the investigation.
  2. The President ensures the investigator is provided with the resources necessary to conduct a thorough investigation.
  3. The investigator coordinates the investigation with legal counsel and the police (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 his or her investigation procedures, findings, conclusions, and recommendations to the President.
  5. The President (or the Audit & Risk Management Committee - in the case of the President) determines whether disciplinary action is warranted.
  6. The Vice-President responsible for the area where the allegation was deemed to have occurred files all electronic and hardcopy files and documents related to the investigation according to the established record retention and archiving schedule.

Reporting the Results of Investigations to the Board of Governors

Cases of wrongdoing that involve loss of money or assets are reported to the Audit & Risk Management Committee at the next regular meeting.

  1. The President submits the investigator’s report to the Audit & Risk Management Committee.
  2. The Audit & Risk Management Committee reviews the investigator’s report and makes its recommendation.

Related Information