Policy 1.3 - Safe Disclosure Policy

The official version of this policy is housed with the University Secretariat.  In the event of a discrepancy, the official version will prevail. Click here for a printable version of this policy. 

Resources related to this policy are available on the Audit Services website.

Approving Authority: Board of Governors 
Responsible Office: Chief Internal Auditor
Responsible Officer: President
Original Approval Date: June 21, 2019
Most Recent Revision Date: N/A
Previous Revisions: None

1. Purpose

1.1.  The University of Guelph is committed to promoting a culture of integrity, transparency and accountability and to that end, has policies or employment agreements which address behaviour that is not consistent with these goals.

1.2.  The purpose of this Policy is to provide a process for submitting Good Faith Reports to University of Guelph authorities of Inappropriate Behaviour (as defined in section 3) (“Report”) where no other process exists under an Alternate Policy.  Investigations will only be undertaken under this policy when other avenues or means to address the concern are exhausted, or, in the University’s sole discretion, are unavailable or for good reason are unacceptable.

1.3.  A concerned University Community Member is encouraged to first disclose the behavior to the person to whom they report, or to their Dean, division head, or a representative in Human Resources, Faculty and Academic Staff Relations, Office of Research, Diversity and Human Rights, Secretariat, or Finance, as appropriate.

2. Jurisdiction/Scope

2.1.  This Policy applies to all University Community Members

2.2.  This Policy is not intended to limit, amend or replace an existing Alternate Policy or employment agreement that has been established for purposes including but not limited to:

2.2.1.  individual complaints, appeals, grievances, management of employee performance or provisions in a collective agreement;

2.2.2.  discrimination, workplace violence or harassment, sexual violence, health and safety or human rights; or

2.2.3.  Appeals, complaints, grievances or issues associated with academic misconduct, research, and intellectual property.

2.3.  Situations where there is an imminent threat to personal safety or University property must be reported immediately to Campus Police.

3. Definitions

3.1.  Alternate Policy: An existing University of Guelph policy that addresses the Inappropriate Behaviour being reported.

3.2.  Good Faith Report: a report regarding actual or perceived Inappropriate Behaviour that is based on reasonable belief and is not frivolous, vexatious, or made in bad faith.

3.3.  Inappropriate Behaviour: an activity which:

  • violates University policies, procedures, or any applicable legislation; or
  • could potentially disrupt the activities of the University, cause harm to our members, impact the public trust and reputation of the University, or result in financial loss to the University.
  • Inappropriate Behaviour may include but is not limited to:
  • falsification, unauthorized alteration or unauthorized destruction of University documents;
  • fraud, misappropriation, theft, embezzlement or misuse of University assets;
  • making false or misleading statements;
  • undisclosed conflicts of interest;
  • endangering the life or safety of another member of the University community; or
  • retaliation for making a Good Faith Report, pursuant to this Policy.

3.4.  Reporter: any individual who makes a report alleging Inappropriate Behaviour under this Policy.

3.5.  University Community Members: includes but is not limited to all staff, faculty, students, volunteers, officers, members of the Board of Governors and Senate, contractors, service providers, professor emeriti, and visiting scholars.

4. Good Faith Report

4.1.  Under this Policy, any individual can make a Good Faith Report to persons in authority at the University. Anonymous Good Faith Reports will be accepted. However a Reporter’s decision to remain anonymous may impact the ability of the University to address the matter.

4.2.  If a Reporter wishes to make a Good Faith Report under this Policy or is uncertain as to which policy may apply in the circumstances, then the mechanism outlined in the Procedures for Safe Disclosure Policy should be utilized.

4.3.  A Good Faith Report should be made in a timely manner and include all relevant details available to the Reporter. Delay in reporting may affect the University’s ability to pursue the matter. 

4.4.  A Good Faith Report may lead to an investigation. To maintain the integrity of an investigation process, the University will take reasonable steps to maintain confidentiality to the extent possible.  Confidentiality may not be possible where identification is required to conduct a thorough investigation, to comply with the law, and to provide accused individuals their legal rights of defense.

4.5.  It is contrary to this Policy for anyone to retaliate, engage in reprisals or threaten to retaliate against a Reporter for making a Good Faith Report under this Policy. Anyone found to have engaged in such conduct may be subject to sanctions or discipline in accordance with the relevant policy or procedures.

4.6.  If the University determines that a report is not a Good-Faith Report, the Reporter may be subject to appropriate disciplinary action and possible legal action.

5. Reporting

5.1.  Subject to section 5.2 below, the Chief Internal Auditor will provide to the President and the Audit & Risk Committee of the Board of Governors, an annual report summarizing the Good Faith Reports received.

5.2.  In addition to the annual report identified in section 5.1 above, the Chair of the Audit and Risk Committee shall be provided with additional updates regarding Good Faith Reports that relate to financial fraud, involve the President or any Vice-President, or pose significant risk to the University.

6. Related Policies, Procedures & Documents

6.1.  Further information on how to file a Good Faith Report and the steps undertaken to investigate them can be found in the Procedures for Safe Disclosure Policy.

6.2.  Alternate Policies may include but are not limited to:

Related Procedures: Procedures for Safe Disclosure Policy