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Procedure for Reporting Fraud (5.18)
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: Vice-President: Finance and Administration
Original Approval Date: April 22, 2021
Date of Most Recent Review/Revision: May 23, 2023
Administrative Responsibility: Vice-President, Finance and Administration
Parent Policy: 5.18 Fraud Policy
1.0. Notification
1.1 Individual suspecting fraudulent activity will notify their supervisor (e.g. Manager/Director) or department Chair or equivalent* immediately. Students suspecting fraudulent activity will notify the Dean of Students Office.
1.2 Manager/Director, department Chair or equivalent*, or Dean of Students Office will immediately notify:
- Their department/faculty lead (AVP (or equivalent), Dean, senior administrator); and
- The Vice-President: Finance and Administration (VP F&A), and the Assistant Vice-President: Financial Resources (AVP FR) who is the Finance and Administration lead for this procedure and responsible to oversee the investigation and resolution of the Fraud Incident.
1.3 The department/faculty lead will take any immediate steps needed within the department/faculty to implement controls and contain further risks.
1.4 VP F&A will notify the Office of the President, members of the Executive Leadership Team (ELT), and members of the University Community as appropriate.
2.0 Investigation and Communication
2.1 Following receipt of notice of a potential Fraud incident, the AVP FR, or designate, shall gather relevant information and details to determine if a Fraud incident has occurred and determine any immediate next steps to address the Fraud, implement controls and contain further risks.
2.2 If the suspected Fraud relates to the AVP FR, the report should be made to the VP F&A who shall appoint an investigator.
2.3 The AVP FR, or designate, shall engage all necessary and appropriate internal and/or external resources and advisors as deemed necessary to complete an investigation of the potential Fraud incident carefully and fairly, respecting privacy and confidentiality as appropriate. When the Fraud Incident may involve criminal conduct, Special Constable Services (SCS) and General Counsel will be notified and consulted as appropriate.
2.4 Prior to engaging any external resources or advisors, the AVP FR and department/faculty lead will ensure that the VP F&A as well as the Office of the President are consulted.
2.5 In investigating the incident, the AVP FR is entitled to meet with or gather information from any Member of the University Community who may have relevant information relating to the potential Fraud incident.
2.5 The AVP FR, or designate, will work with the relevant internal department/faculty resources to complete:
- A thorough summary of the instance, the impact to the university, mitigation actions taken and resulting status.
- An assessment of existing operational risk management practices and identification of internal control improvements required.
- Status of internal control improvement efforts.
- Additional information that may be required, determined by the VP F&A, to inform the Office of the President, ELT, or Members of the University Community.
2.6 AVP FR will work closely with the affected area to ensure that appropriate risk mitigations strategies and internal controls are put in place to address the incident and shall provide updates regarding the incident and the mitigating actions being taken are communicated expeditiously to the VP F&A.
2.7 VP F&A will ensure that the Office of the President, members of ELT, and other Members of the University Community are kept updated as relevant information becomes available.
2.8 The AVP FR will maintain a register of fraud instances including summary reports and status updates.
2.9 The VP F&A, or designate, shall report to the Audit, Risk and Compliance Committee, on all significant detections of Fraud and the corrective activities undertaken.
*program coordinator, area coordinator or Associate Dean (for non-departmentalized Faculties)