Institutional Integrity

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 First Nations University of Canada,and
• All members of University committees 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.

This policy offers members an avenue for reporting allegations of wrongdoing when other University policies and processes prove ineffective.

Definitions

Employee: a person who receives a salary from the University for full-time or part-time work or services normally performed by an employee. This includes a person currently on an employment leave.

Allegation: an unproven but formal, written assertion or claim that someone has done something wrong.

Wrongdoing: any violation of federal, provincial, or municipal law and regulations, any violation of University policy, including the University’s Code of Conduct; unethical conduct.

Disclosure: the act of making something evident; revealing information; any revelation concerning an actual or perceived wrongdoing.

Anonymous: of unknown authorship; not named or identified

Accused: a person against whom the allegation of wrongdoing is made

Investigator: any person appointed to conduct an investigation of potential wrongdoing

Complainant: person who makes an allegation or complaint against another person

Fraud: Theft, misappropriation or misuse of funds or property or any illegal act to deceive others resulting in the victim suffering a loss and/or the perpetrator achieving personal or business gain.

Examples of fraud include but are not limited to:

• A financial system accounting entry intentionally made to represent what is not true or does not exist,
• Unauthorized alteration or use of financial documents and systems,
• Forgery of a signature, cheque, bank draft, or any other financial transaction document,
• Misappropriation of funds, supplies, or assets,
• Theft of property and identity,
• Misrepresentation of identity,
• Disclosure of confidential information to external entities for personal gain,and
• Unauthorized destruction, removal, or use of records for personal gain.

Retaliation: any negative or adverse action to a person in response to an action, e.g., his or her allegation, disclosure, or investigation of an alleged wrongdoing

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 President
• The Chair of the Board of Governors’ Audit, Finance and Risk 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, or the Chair of the Audit, Finance and Risk Committee (in the case of 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, Finance and Risk Committee when an allegation is received. In the case of the President, the Chair of the Audit, Finance and Risk Committee will inform the Chair of the Board of Governors.

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, Finance and Risk Committee (in the case of the President).

If an investigation indicated that fraud might have occurred, the Board of Governors (or designate) will contact the University’s insurance company, the External Auditor, the University of Regina, and the police (as required and 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 President 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.

Related Information

• Institutional Integrity Policy – Procedure Statement
• Code of Conduct Policy
• Records Management and Retention Policy