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Safe Disclosure Policy

  • Related Documents:  Safe Disclosure Procedure

  • Owner:  Vice-President, Administration and Operations
  • Approver:  Board of Governors
  • Approval Date(s):  June 2017

I.    Purpose

Toronto Metropolitan University (the “University”) is committed to maintaining the highest standards of financial accountability in all of its activities, and encourages individuals who have evidence of fraud, theft or misappropriation of University resources (as defined below) to disclose such evidence to individuals in authority.

This policy:

a.    confirms the University’s commitment to take seriously, and promptly respond to, allegations of improper financial activity;

b.    enhances the University’s accountability to the public trust, adherence to all applicable laws and University policies, and ensuring fair treatment;

c.    establishes the procedures for confidential disclosure that protect individuals against interference, reprisals or retaliation when they report incidents of alleged wrongdoing in good faith; and

d.    promotes the University’s people-first values of integrity, equity, collegiality and inclusion.

II.    Scope and Application

This Policy and its associated Procedure apply to all employees, agents, contractors, volunteers and any others acting on behalf of the University or doing business with the University.

It is not intended to apply to other various acts of misconduct that are dealt with through the following offices and policies:

a.    Issues that involve discrimination and harassment should be referred to Human Rights Services in accordance with the Discrimination and Harassment Prevention Policy or through provisions in the relevant collective agreement.

b.    In cases of suspected academic dishonesty, matters should be reported in accordance with the appropriate policy:  (PDF file) Academic Integrity;  (PDF file) Scholarly, Research and Creative Activity (SRC) Integrity.

c.    In the case of an alleged conflict of interest, the provisions in the Conflict of Interest Policy and/or Conflict of Interest Procedure should be followed.

d.    Issues related to violations of the Occupational Health and Safety Act or other similar applicable law, rule or regulation relating to the environment, working conditions or workplace safety and security, should be reported to the Environmental Health and Safety Office.

e.    Individuals with concerns about unethical behaviour that may be addressed through provisions of a collective agreement or other employment agreement governing their relationship with the University should follow the process identified by the relevant agreement.

In each of the above instances, investigation and reporting will occur in accordance with the relevant policy or agreement.

III.    Definitions

For the purposes of this Policy and the accompanying Procedure:

“fraud, theft, or misappropriation of University resources” include, but are not limited to:

a.    misappropriation or unauthorized use of University property and resources;

b.    forgery or alteration of documents;

c.    bribery or collusion;

d.    authorizing or receiving payment for goods not received or services not performed;

e.    authorizing or receiving payment for hours not worked;

f.    any claim for reimbursement of expenses that are not incurred for the benefit of the University; and

g.    any computer-related activity involving the alteration, destruction, forgery or manipulation of data for fraudulent purposes.

“good faith” refers to reporting made for the purpose of remedying the condition and not for a frivolous, vexatious or extraneous purpose.

IV.    Policy

1.    The University is committed to providing an environment where individuals may disclose, in good faith, their concerns about improper financial activity that has occurred or could potentially occur, without being subject to reprisal of any kind. 

2.    Individuals who have made allegations in good faith or provided information related to an allegation will not be subject to reprisal.  

3.    This policy is in addition to and does not replace the rights or responsibilities of an individual under law, employment contract or professional ethics.

4.    To allow a competent investigation to be completed, no individuals involved in a disclosure 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.     

5.    Any individual who experiences any type of reprisal as a result of reporting improper financial activity under this Policy should immediately inform the Chief Human Resources Office.

6.    The formal procedure for disclosure and investigation of possible wrongdoing is set out in the Safe Disclosure Procedure. 

V.    Roles and Responsibilities

Chief Human Resources Office: may receive disclosures; may participate in the investigation of alleged financial impropriety; receives any employee reports of reprisals following a disclosure.

Chief Internal Auditor: may receive disclosures; verifies that the alleged financial impropriety can be substantiated within reason; leads and coordinates the investigation of alleged financial impropriety; prepares the findings for communication to appropriate senior University Officers and the Audit Committee of the Board of Governors.

Chief Financial Officer: may receive disclosures; may participate in the investigation of alleged financial impropriety; has duty to communicate findings to the external auditor.

General Counsel: may receive disclosures; may participate in the investigation of alleged financial impropriety; advises on limits of confidentiality.