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5.18 Fraud Policy

5.18 Fraud Policy

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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.

Approving Authority: Board of Governors

Original Approval Date: April 22, 2021

Date of Most Recent Review/Revision: February 16, 2023

Office of Accountability: Vice-President: Finance and Administration

Administrative Responsibility: Office of Financial Resources

1.00 Purpose

1.01 The purpose of this policy is to ensure effective communication, reporting, disclosure, and investigation of Fraud occurrences that present a risk to Wilfrid Laurier University (Laurier), which will facilitate the development of controls to aid in the detection and prevention of future instances of Fraud. In addition, this policy aims to raise awareness to such activities and facilitate the ongoing implementation and improvement of Internal Controls designed to mitigate these risks.

2.00 Definitions

2.01 Employees: A person who performs work for wages in any capacity for the University.

2.02 Fraud: Defined as the intentional deception, false representation or concealment of facts for the purpose of personal gain to obtain an advantage for oneself or for one or more third parties, or to avoid an obligation. Fraud includes inducing another party to act upon intentional deception, false representation or concealment to that party’s injury or financial loss. Fraud can occur in different ways and through mechanisms that continue to evolve in tactics and sophistication. Examples of actions constituting Fraud include, but are not limited to:

  1. Academic fraud, including but not limited to altered or forged transcripts, forged letters of permission, forged credential documents
  2. unauthorized use of digital signatures or alteration of signed documents
  3. resume fraud;
  4. forgery or alteration of a cheque, bank draft, financial instruments, or any documents or accounts;
  5. payroll Fraud (e.g. paycheque theft, timesheet Fraud);
  6. unauthorized use of University assets for personal gain;
  7. destruction or theft of funds, securities, supplies, or other assets;
  8. false accounting or any impropriety in the handling or reporting of money or financial transactions;
  9. attempts to obtain sensitive information such as usernames, passwords, credit card details, confidential or proprietary information, by disguising as a trustworthy individual or company;
  10. profiteering as a result of insider knowledge of Laurier client activities.
  11. engaging in bribery; giving or accepting money or favour in order to influence the judgment or conduct of a person in a position of trust or influence

2.03 Internal Controls: Are processes and systems put in place to provide reasonable assurance that assets are safeguarded and that these processes and systems effectively manage risk and diminish the occurrence of Fraud.

2.04 Member(s) of the University Community: Persons who currently live, work, or study (in person or online) on any Laurier campus. Members include Students (including student groups), Employees, adjunct and visiting faculty, and volunteers at Laurier.

3.00 Jurisdiction/Scope

3.01 This policy applies to all Members of the University Community.

4.00 Policy

4.01 Guiding Principles

a. Laurier is committed to maintaining the highest standard of honesty, integrity and transparency in its activities and to protecting itself against Fraud.

b. All Members of the University Community are expected to consistently demonstrate and promote professional conduct, ethical behaviour, and integrity by familiarizing themselves with and complying with Laurier policies and procedures.

c. Laurier has a duty to ensure its commitment to ethical practices and the establishment of mechanisms for addressing deviations from expected ethical behaviours.

d. Fraud, in any form, will not be tolerated.

e. Faculty and departmental managers are responsible for the ongoing mitigation of risks including Fraud risk, and are accountable for establishing, maintaining and monitoring controls to effectively mitigate such risks in their units.

f. Members of the University Community who report acts of suspected Fraud may do so freely and without fear of reprisal as per Policy 5.14 Safe Disclosure.

4.02 Reporting Potential Fraud

4.02.01 Any Member of the University Community who suspects Fraudulent activity is to immediately report it in accordance with the procedure detailed in the Procedure for Reporting Fraud. All instances and reported cases of Fraud will be investigated and reported to the appropriate authorities.

4.02.02 In cases where fraudulent activity pertains to Academic Misconduct, policy 12.2 Student Code of Conduct, and related procedures, are required to be followed. Reporting obligations for instances of fraud pertaining to Academic Misconduct will be addressed though the Central Registry reporting requirements outlined in policy 12.2, with the exception of any instances that are deemed to be of significant risk to the University, or require the engagement of external resources or advisors. Those instances are required to be reported through the Fraud Policy and Procedures, in addition to the requirements set out in policy 12.2.

4.02.03 In cases where fraudulent activity pertains to Research Misconduct, policy 11.14 Policy for the Responsible Conduct of Research, and related procedures, are required to be followed. Any instances that are deemed to be of significant risk to the University, or require the engagement of external resources or advisors, are required to be reported through the Fraud Policy and Procedures, in addition to the requirements set out in policy 11.14.

4.02.04 The reporting individual will not contact the suspected individual or company in an effort to determine facts or demand restitution without auhtorization by the VP, F&A.

4.02.05 The reporting individual is not to discuss the specifics of the case, facts, suspicions, or allegations with anyone not indicated in the Procedure for Reporting Fraud without confirming in writing it is appropriate to do so from the Office of the General Counsel, Special Constable Services (SCS) or if such disclosure is required by court order.

4.02.06 Prior to engaging external resources or advisors, the office of the VP, F&A is required to be consulted.

4.02.07 Employees who commit an act of Fraud are subject to disciplinary action, up to and including termination with cause, as well as possible criminal charges.

4.02.08 Employees who make vexatious reports of Fraud will be investigated and are subject to disciplinary action, up to and including termination with cause.

4.02.09 Failure to report a suspected Fraud may result in an investigation of the employee who is aware of the fraud but fails to report it as well as an investigation of the Employee(s) who actively commits the Fraud.

4.02.10 Members of the University Community shall not be subject to any discrimination, threats, reprisals, or disciplinary action as a consequence of reporting a suspected Fraud and/or acting as a witness in an investigation or court proceeding in relation to an alleged Fraud.

4.02.11 Laurier will pursue full recovery of all losses resulting from an act of Fraud.

5.00 Roles and Responsibilities

5.01 Members of the University Community are responsible for reporting suspicions of Fraud as defined by this policy and to provide cooperation with any investigation being carried out. In addition, management is responsible to detect and prevent Fraud within their respective areas and to be aware of Fraud activities that may occur. Members of the University Community are responsible for participating in the process of creating a strong control environment.

5.02 Academic and administrative managers are responsible for implementing good operational risk management practices and maintaining appropriate internal Controls that support the effective management of risk per Policy 5.16 Risk Management Policy. Effective risk management requires timely recognition and disclosure of potential risks and should be incorporated into departmental/unit planning processes and management activities. Managers are responsible for the ongoing mitigation of risks including fraud risk, and are accountable for establishing, maintaining and monitoring controls to effectively mitigate such risks. Managers are accountable for implementation of this policy within their respective areas of responsibility.

5.03 Within the Board of Governors, the Audit, Risk and Compliance Committee is responsible for supporting and overseeing the implementation of the university’s Enterprise Risk Management (ERM) program, which includes risk management pertaining to instances or potential for Fraud. The Board of Governors and senior management is responsible for periodically reviewing the ERM program as well as applicable Laurier policies and procedures designed to help mitigate Fraud risk.

5.04 The Office of the Vice-President Finance and Administration is responsible for the interpretation and application of this Policy.

5.05 The Financial Resources Office is responsible for developing training and awareness activities pertaining to financial Fraud risk. This also includes the dissemination of existing, emerging and potential Fraud incidences to both Finance and non-Finance personnel accompanied by a regular review of training procedures and content ensuring strong financial Internal Controls are in place.

6.00 Confidentiality

6.01 Confidentiality of the identity of the individual reporting the Fraud is maintained unless disclosure is required to further investigate the incident or as required by law.

6.02 The details of an investigation, analysis of the facts, allegations and conclusions will be disclosed only to those persons who need the information for the investigation, for the implementation of the decision or unless required by this Policy or by law.

Relevant Legislation

Related Policies, Procedures, and Documents

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