Fraud Deterrence Policy

Responsibility: Vice-President, Finance and Resources 
Authorization: Board of GovernorsUniversity Council
Approval Date: Jul 29, 2014

The University of Saskatchewan 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 the university’s position with respect to fraud, irregularities and other wrongdoing.
• Foster an environment that promotes fraud awareness.
• Facilitate and support the development of controls to aid in the prevention and detection of fraud.
• Confirm the shared responsibility of all university members to report suspicions of fraud or irregularity or other wrongdoing as defined by this policy.
• Articulate the process to be followed in responding to reports of alleged fraudulent activity.
• Evaluate the risk of fraud and implement best practices in processes, procedures and controls that are necessary to mitigate the identified risks, and reduce the opportunities for fraud.
• Develop an effective and appropriate oversight process.

This policy is founded on, and embodies, the following guiding principle:

• Create and maintain a culture of honesty, integrity, accountability and ethical behavior.

This policy applies to all university members, including the Board of Governors and all individuals and parties acting on behalf of the University of Saskatchewan. 

The scope of this policy is limited to activities related to, or funds or property owned by, or in the care of, the University of Saskatchewan.  Allegations or identification of acts other than fraud, are outside the scope of this policy, and will be resolved with reference to the appropriate university policies, regulations or guidelines.

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

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

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

The university, as represented by the Board of Governors and senior 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 the University of Saskatchewan.

University 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.

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

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

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

All university 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, university policies and collective agreements in effect at the time the alleged fraud or irregularity was committed.

The university, as represented by the Board of Governors and senior management, is responsible for: setting the appropriate ‘tone at the top’; establishing effective controls and procedures to prevent and detect fraud, irregularities and other wrongdoing; and maintaining an effective oversight process to safeguard the university’s assets and resources.

The University Auditor is responsible for providing objective assurance to the Board of Governors that effective and sufficient controls are in place for the identified fraud risks; and has primary responsibility for the investigation of suspected fraudulent acts covered by this policy.

University members must not tolerate any fraudulent activity, irregularities or unethical activities.

University members are expected to consistently demonstrate and promote professional conduct, ethical behavior, and integrity by complying with all applicable university policies and procedures, laws, rules, regulations and applicable professional codes of conduct.

Any university member who suspects any irregularity, wrongdoing or fraudulent activity is to immediately report it in accordance with the procedures detailed in the university’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 the university’s Safe Disclosure Reporting Mechanism – Operating Guidelines and Investigation Guidelines.

The university expects that its members will comply fully with this policy, including all requirements for disclosure.  Failure to do so 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 university members involved in an investigation of fraud, irregularity or wrongdoing must keep the details and results of the investigation confidential, in order to safeguard and protect the rights of those involved in the allegations, and preserve the legal validity of all evidence collected.

The university 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 university 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.

• 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