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5.14 Safe Disclosure

5.14 Safe Disclosure

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

Office of Accountability: Office of the President

Administrative Responsibility: University Secretariat

1.00 Purpose

1.01 The purpose of this policy is to:

a. Provide a disclosure mechanism through which anyone can confidentially disclose, in good faith, a Wrongdoing by a Member of the University Community observed in the context of performing their duties or activities pertaining to University business; and

b. To protect those Members of the University Community who, in good faith, make such reasonable disclosures of Wrongdoing by prohibiting subsequent Reprisals against them.

1.02 This policy is not designed to question legitimate financial, administrative or business decisions taken by the University through its normal processes, nor should it be used to reconsider any matters which have already been addressed under the appropriate policies, procedures, or collective agreements.

2.00 Definitions

2.01 Employee: a person who performs work for wages in any capacity for the University.

2.02 Good Faith 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.

2.03 Member(s) of the University Community: persons who currently work or study (in person or online) on any 51��ɫ campus. Members include students (including student groups), Employees, adjunct and visiting faculty, and volunteers at 51��ɫ.

2.04 Reprisal: any adverse action, or threat of an adverse action, taken against a person for:

a. making a Good Faith Disclosure;

b. supporting the filing of Good Faith Disclosure;

c. participating in an investigation of Good Faith Disclosure;

d. declining to participate in Wrongdoing

e. or doing anything in accordance with this policy.

2.05 Student: An individual registered in a course of study as a student at the University, either full-time or part-time, pursuing undergraduate, graduate, or non-degree certificate programs.

2.06 Wrongdoing: the following acts or conduct engaged in by a Member of the University Community pertaining to University business:

a. a violation of a legal or regulatory requirement;

b. significant breach of University policy and/or procedures

c. unethical conduct

d. abuse of public trust

e. theft, fraud, misappropriation of University assets, forgery, falsification or alteration of documents

f. destruction, removal or concealment of University records or property for the purpose of personal gain;

g. corruption including the offering, giving, receiving or soliciting, directly or indirectly, anything of value to influence improperly the actions of others;

h. making false claims or statements;

i. collusion with the aim of achieving an improper purpose or influencing the actions of another party in the commission of a Wrongdoing;

j. gross mismanagement or abuse of authority in the context of performing their duties or responsibilities within the University;

k. any act or omission that could potentially disrupt the activities of the University, impact the public trust and reputation of the University, or result in financial loss to the University; or

l. conduct which is considered a Reprisal pursuant to this Policy.

3.00 Jurisdiction/Scope

3.01 This policy applies to all Members of the University Community.

3.02 Nothing in this policy shall limit or supersede any legal requirement or binding agreement entered into by the University, or policies or procedures.

4.00 Policy

4.01 51��ɫ is committed to maintaining the highest ethical standards in all of its activities and immediately acting on any Wrongdoing. Members of the University Community are expected to act with integrity and honesty and to protect University property and public funds for which they are responsible. With this policy, the University aims to protect any Member of the University Community who acts to expose Wrongdoing within the University.

4.02 As a result of their involvement in the University’s day-to-day operations, Employees and Students are often in the best position to observe and report unethical conduct or abuse of the public trust. In keeping with the University’s commitment to accountability and transparency, the University will maintain an environment of safe disclosure for good faith reporting of Wrongdoing (“whistleblowing”).

4.03 Concerns or allegations of Wrongdoing shall be reported and addressed in accordance with the existing University policies or procedures that govern the activity in question.

4.04 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 immediately to persons in authority at the University in accordance with the procedures related to this policy.

4.05 A Good Faith Disclosure should be made to the next appropriate supervisor or manager. If the Wrongdoing may involve the next appropriate supervisor or manager or member of senior university administration (i.e. University President or Vice-Presidents), the Good Faith Disclosure should be made to the Assistant Vice President, Governance & Policy (AVP, Governance & Policy). If the Wrongdoing may involve the AVP, Governance & Policy, the disclosure should be made to the General Counsel and Chief Legal Officer.

4.06 The University shall take all necessary and appropriate action to carefully and fairly investigate and respond to disclosures of Wrongdoing, including legal action as appropriate.

4.07 No individuals involved in a disclosure, allegation or an investigation under this Policy shall disclose or discuss the details and results of an investigation with anyone other than those personnel associated with the University who have a need to know such details and results in order to perform their duties and responsibilities. Details and results of investigations shall be kept confidential within the limitations of the law, collective or employee agreements and University policies.

4.08 The University will use all reasonable efforts to keep the details of a Good Faith Disclosure confidential, and shall protect the identity of the person making the Good Faith Disclosure to the extent possible under legislation, regulation, University policy, and collective agreements in effect at the time of the disclosure.

4.09 All persons involved in allegations of Wrongdoing are to be treated fairly and impartially and maintain the rights, privileges and protections afforded to them under legislation, University policies and collective agreements in effect at the time of the alleged Wrongdoing.

4.10 It is contrary to this Policy for anyone to retaliate and engage in Reprisals. The University will investigate and take all appropriate action to address all allegations of Reprisal.

5.00 Non-Compliance

5.01 Any person who knowingly makes an allegation of Wrongdoing which is false, frivolous, vexatious, made in bad faith, or shares confidential information as specified in section 4.08 will be subject to disciplinary action, up to and including termination, as appropriate.

6.00 Reporting

6.01 An annual report shall be provided to the Audit, Risk & Compliance Committee of the University Board of Governors in accordance with the reporting requirements in the procedures relating to Safe Disclosure Policy.

6.02 The AVP, Governance & Policy shall provide notice to the Audit, Risk and Compliance Committee regarding Good Faith Disclosures that involve the President or any Vice-President, or pose significant risk to the University.