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Procedure for Reporting and Investigating Fraudulent Activity

Approval Date: 2017-05-11

Effective Date: 2017-05-11

Responsible Unit: Office of Internal Audit


1.Any Member of the University who becomes aware of Fraudulent Activity involving conduct by anyone other than as listed in section 2 below may report such to the University Auditor. To appropriately assess the report and to undertake further steps, the Member should provide the following:

a)the party(ies) involved;
b)the nature of the suspected Fraudulent Activity;
c)the date(s) of the Fraudulent Activity;
d)any other information necessary to evaluate the matter.

2.If the suspected Fraudulent Activity involves conduct of a Vice-President, the report should be filed with the President. If the suspected Fraudulent Activity involves conduct of the President, the report should be filed with the Chair of the Board of Regents. If the suspected Fraudulent Activity involves conduct of the Office of Internal Audit, the report should be filed with the Chair of the Audit and Risk Committee.

3.Reports can be made verbally or in writing, and can be made openly, confidentially or anonymously. Reporting an allegation anonymously may affect the University's ability to conduct an investigation.

4.All reports of Fraudulent Activity shall be communicated to the University Auditor, as per the Internal Audit Activity Charter.

5.After reviewing the information provided, the University Auditor shall decide whether further action is warranted. In making this determination the University Auditor uses a risk-based approach, considers other existing mechanisms within the University's policy and procedures for addressing the suspected Fraudulent Activity and may consult, as appropriate.

6.Any person(s) suspected of Fraudulent Activity should not be confronted prior to commencement of any investigation.

7.Records related to the activity may need to be seized before the suspected person(s) becomes aware of any investigation.

8.Any investigation shall consider requirements within applicable collective agreements.

9.The University Auditor shall advise any persons interviewed to treat information, evidence and proceedings with confidentiality, as appropriate.

10.The results of any investigation shall be presented to the applicable Unit Head and others, as appropriate. Law enforcement agencies will be notified in cases where it is determined that criminal charges may be warranted. Any decision to refer investigation results to a law enforcement agency will be made by the President, in consultation with the Office of the General Counsel.

Policies using this procedure:


University Policies

230 Elizabeth Ave, St. John's, NL, CANADA, A1B 3X9

Postal Address: P.O. Box 4200, St. John's, NL, CANADA, A1C 5S7

Tel: (709) 864-8000