Institutional Integrity Policy – Procedure Statement

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:
   a. Their supervisor
   b. The President
   c. The Chair of the Audit, Finance and Risk Committee (in the case of the President).
2. 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.
3. The person who received the report forwards it to the President or the Chair of the Audit, Finance and Risk Committee (in the case of the President).
4. As urgently as possible and not later than seven (7) business days of the report, the President or Chair of the Audit, Finance and Risk Committee (in the case of the President) reviews the complaint and determines if an investigation is warranted.
5. If an investigation is warranted, the President or the Chair of the Audit, Finance, and Risk Committee (in the case of the President) appoints a lead investigator or investigating team.
6. 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 or Chair of the Audit, Finance and Risk Committee (in the case of 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 or the Chair of the Audit, Finance and Risk Committee (in the case of the President).
5. The President or the Chair of the Audit, Finance, and Risk Committee (in the case of the President) determines whether disciplinary action is warranted.
6. The President’s Office 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

1. The President submits the investigator’s report to the Audit, Finance and Risk Committee
2. The Audit, Finance and Risk Committee reviews the investigator’s report and makes its recommendation to the Board of Governors.
3. In the case of the President, the Chair of the Audit, Finance and Risk Committee submits the investigator’s report directly to the Board of Governors.