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June 27, 2017

This online version is for convenience; the official version of this policy is housed in the University Secretariat. In case of discrepancy between the online version and the official version held by the Secretariat, the official version shall prevail.

These procedures set out the process and guidelines to facilitate the safe disclosure and investigation of Wrongdoing under Policy (5.14).

Disclosure

1.00 In accordance with the Safe Disclosure Policy, any faculty, staff, student or volunteer who has information and reasonable grounds to believe there has been Wrongdoing is encouraged to make a Good Faith Disclosure to persons in authority at the University.

2.00 Disclosures of Wrongdoing (“Disclosures”) should be made in a timely manner and generally within thirty (30) days of discovering the Wrongdoing.

3.00 Disclosures should be made in writing and signed.

Investigation

4.00 The supervisor or manager to whom a Disclosure is made shall notify the University Secretary and General Counsel or Chair of the Audit and Compliance Committee of the Board of Governors, in accordance with the Safe Disclosure Policy, who shall be responsible to appropriately review and investigate the Disclosure (the “Investigator”).

5.00 The Investigator shall consider whether the Disclosure is outside the scope of this Policy or may be resolved with reference to other University policies or guidelines which appropriately address them (e.g., those on harassment, or academic misconduct).

6.00 The Investigator will investigate any disclosure of Wrongdoing carefully and fairly, respecting privacy and confidentiality as appropriate.

7.00 The Investigator is entitled to require the person(s) who have made the Disclosure to meet with her/him to discuss the allegation and provide all available information supporting the allegation. In conducting the investigation, the Investigator shall also be entitled to request a confidential meeting with any member of the University community who may have relevant knowledge of the matter.

8.00 In all investigations, the individuals against whom an allegation of Wrongdoing is made (the “Respondent(s)”) shall be given a summary of the information gathered in the investigation and a reasonable opportunity to provide a written response to the alleged conduct or complaint and the opportunity, if requested, to meet with the Investigator.

9.00 The Investigator shall have access to the external auditor of the University, external legal counsel, and such other advisors as deemed necessary to complete the investigation.

10.00 The Investigator shall deliberate carefully and determine whether misconduct or wrongdoing has occurred. The Investigator will submit a written report to the University President outlining his/her findings and recommendations. Where there is a finding of wrongdoing, he/she shall also provide a copy of the decision to the appropriate internal supervisor or manager for a determination on discipline.

11.00 Prior to taking any disciplinary action, the University will provide to the Respondent(s) written notice of the finding of the investigation. The Respondent(s) and will have seven (7) working days following the date of this notice to provide a written response.

12.00 To maintain confidentiality, the results of individual investigations will be reported only to those parties with a need to know as determined by the President (or his or her designate).

Reporting

13.00 The University Secretary and General Counsel, or designate, shall annually provide a report to the Audit and Compliance Committee of the University Board of Governors which report will include a summary of the number, nature and disposition of all investigations made under this policy. This report, together with any recommendations, will be provided to the Board of Governors, normally at its annual meeting.

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