Fraud Deterrence Policy

The University of Saskatchewan (USask) recognizes the importance of protecting the institution, and its operations, assets, employees, and reputation from the consequences of fraudulent activity.

The purpose of this policy is to:

• Clearly state USask’s position with respect to fraud, irregularities and other wrongdoing. 
• Foster an environment that promotes fraud awareness. 
• Facilitate and support the development and management of a system of internal controls to support the prevention and detection of fraud. 
• Confirm the shared responsibility of all USask members to report suspicions of fraud, irregularity, or other wrongdoing. 
• Require USask to have a process for responding to reports of alleged fraudulent activity. 
• Require the evaluation of fraud risk and the implementation of processes, procedures and internal controls to effectively mitigate risks, and reduce the opportunities for fraud. 
• Require management maintain an effective and appropriate reporting and oversight process.

To create and maintain a culture of honesty, integrity, accountability and ethical behaviour.

USask, as represented by the Board of Governors and management, is committed to maintaining the highest standards of honesty, integrity and ethical conduct.  Fraud, or the concealment of fraud, will not be tolerated at USask. 

Any investigation process required will be carried out without regard to the alleged wrongdoer’s length of service, position/title, or relationship to USask. 

USask members who are found to have committed an act of fraud or other impropriety will be subject to disciplinary action up to and including termination of employment, and legal prosecution, if appropriate. 

USask, to the extent reasonably possible, will recover any losses incurred through fraud or financial improprieties. 

All USask members have an obligation to report suspected fraud, irregularities or wrongdoing. 

USask members will adhere to the principles of ethical conduct and reporting of wrongdoing contained in USask’s approved codes of conduct (including all applicable professional codes of conduct), and Safe Disclosure Policy. 

All USask members involved in an investigation of alleged fraud or irregularity will retain and be accorded the rights, privileges and protections provided to them through the applicable labor legislation, USask policies and collective agreements in effect at the time the alleged fraud or irregularity was committed. Where a conflict exists between this policy and a collective agreement, the terms of the collective agreement shall prevail. 

Any USask member who suspects any irregularity, wrongdoing or fraudulent activity is to immediately report it in accordance with the procedures detailed in USask’s Safe Disclosure Reporting Mechanism - Operating Guidelines, and cooperate fully when requested in all resulting investigations.  

All reported allegations of fraudulent activity, irregularities or wrongdoing will be responded to and investigated in accordance with the processes and procedures identified in USask’s Safe Disclosure Reporting Mechanism – Operating Guidelines and Investigation Guidelines, in coordination with Human Resources and the General Counsel Office.

This policy applies to all individuals who wish to report a known or suspected fraud affecting USask funds, property, or assets in the care of the USask.  

Academic fraud or dishonesty committed by USask members is also governed by other USask policies and regulations, such as: 

• Regulations on Student Academic Misconduct 
• Standard of Student Conduct in Non-Academic Matters and Regulations and Procedures for Resolution of Complaints and Appeals 
• Responsible Conduct of Research Policy 

Allegations or identification of acts other than fraud, are outside the scope of this policy, and will be resolved with reference to the appropriate USask policies, regulations or guidelines.

Board of Governors and Management

Is responsible for setting the appropriate ‘tone at the top’ and receiving annual reports from management and the auditors that internal controls are in place and effective.

Management

Is responsible for leading by example the ‘tone at the top’; establishing effective controls and procedures to prevent and detect fraud, irregularities and other wrongdoing; maintaining an effective system of internal controls and oversight process to safeguard USask’s assets and resources; and providing annual testing and certification over the effectiveness of internal controls to prevent material misstatements to the Board of Governors.

External Auditor

Is responsible for issuing an opinion to the Board of Governors, through the Audit and Finance Committee, providing reasonable assurance about whether the consolidated financial statements as a whole are free from material misstatement, whether due to fraud or error. 

Internal Auditor

Has primary responsibility for the investigation of suspected fraudulent acts.

USask Community

Members of the USask community, which includes Faculty, staff, students, volunteers, donors and others involved with USask activities must not tolerate any fraudulent activity, irregularities or unethical activities.
USask members are expected to consistently demonstrate and promote professional conduct, ethical behavior, and integrity by complying with all applicable USask policies and procedures, laws, rules, regulations and applicable professional codes of conduct.

The USask community is expected to comply with this policy, including all requirements for disclosure.  Failure to do so by USask members may constitute grounds for disciplinary action in accordance with any applicable collective agreement, employment contract, or student academic or non-academic discipline, regulations, or other applicable disciplinary process.

All USask members involved in an investigation of fraud, irregularity or wrongdoing must keep the details and results of the investigation confidential, to safeguard and protect the rights of those involved in the allegations, and preserve the legal validity of all evidence collected. 

USask will protect the confidentiality of individuals and events under investigation, except where disclosure is required by law.  The details and particulars of any investigation will not be disclosed or discussed with any individuals or parties other than those deemed necessary for investigation purposes, or as required by law. 

Following an investigation, if a USask member, or any other individual, is determined to have committed fraud, an irregularity, or other wrongdoing, this information can be disclosed to the extent allowable by law.

The source of institutional approved definitions is in the Academic and Curricular Nomenclature.

• Academic and Curricular Nomenclature 
• Safe Disclosure Reporting Mechanism - Operating Guidelines 
• Safe Disclosure Reporting Mechanism - Investigation Guidelines
• Appendix A - Fraud Deterrence Program Definitions
• Safe Disclosure Policy
• Conflict of Interest Policy
• Regulations on Student Academic Misconduct
• Standard of Student Conduct in Non-academic Matters
• Responsible Conduct of Research Policy
• University Learning Charter