The University of Manitoba values accountability and integrity and desires to protect its funds and property owned by, or in the care of the university, from fraud and irregularities. In support of this, Audit Services conducts special reviews of reported concerns.
When does a review happen?
Reviews could be initiated to address allegations of misuse of resources, significant control weaknesses, neglect or override of internal controls, or any other activity that is perceived to be contrary to the ethical values of the university.
Reviews may also be undertaken because of requests by senior management or from findings identified during an audit.
We also support the Vice-President (Administration), who is the university's Designated Officer under the Safe Disclosure (Whistleblower) Policy, in responding to disclosures received pertaining to allegations of financial wrongdoing submitted under the Policy.
Fraud and Financial Irregularity Reporting Policy
All university employees have a duty to report any suspicion of fraud or irregularities.
Generally, individuals should first contact their immediate supervisor or university faculty or unit financial manager to discuss concerns in a timely manner. This is an important step because there may be clarifying information that supervisors or others are aware of that may immediately resolve the concern. Individuals can contact Audit Services if they are hesitant to work with their faculty or unit contacts.
Audit Services will evaluate the individual’s concerns to determine if a review is required. The individual reporting the issue may be contacted to obtain additional information. Information received by Audit Services will be treated in a confidential and sensitive manner.
We may determine that the concerns reported would be better addressed under the Safe Disclosure (Whistleblower) Policy or the Responsible Conduct of Research Policy. We will provide guidance and support for filing reports under these policies if that is determined to be necessary.
Definitions of fraud and financial irregularities
Fraud is any illegal act characterized by deceit, concealment, or violation of trust. These acts are not dependent upon the threat of violence or physical force. Frauds are perpetrated to obtain money, property, or services; to avoid payment or loss of services; or to secure personal or business advantage.
Financial irregularities are broader than fraud and include violation or deliberate disregard of university financial policies and ethical standards, or questionable accounting practices. Financial irregularities also include excessive spending, waste, or failing to properly safeguard and protect assets.
Examples of Fraud and Financial Irregularities include, but are not limited to:
- Stealing from the cash register or petty cash.
- Collecting cash receipts from customers and not recording them.
- Authorizing or receiving payments for goods not received or services not performed.
- Any claim for reimbursement of expenses that were not incurred for the benefit of the University or for which the individual had already received reimbursement.
- Fabricated receipts.
- Purchasing personal items on the university purchasing card or through a travel and business expense claim.
- Payroll manipulations such as claims for hours not worked (including overtime), unrecorded vacation, unauthorized pay rate adjustments, or adding non-existent employees to payroll.
- Changing direct deposit information on a vendor or employee or depositing a cheque to a personal account.
- Theft or use of the university’s property (inventory, gift cards, equipment and supplies, intellectual property) for personal advantage or gain.
- Receipt of kickbacks or gratuities from vendors.
- Bid rigging and bribery related to purchasing transactions.
- Failure to appropriately identify and address any real, potential, or perceived conflict of interest.
- Breach of fiduciary duty, such as through neglect, override of internal controls, or intentional failure to act.
- Altering or deliberately recording incorrect financial information for either a personal or university advantage.
- Aiding fraud by other parties.
- Unauthorized staff signing approval documents (forgery).
- Any other activity that deliberately misrepresents or conceals material facts, disregards University policies, internal controls or is perceived to be contrary to the ethical values of the university.
Safe Disclosure (Whistleblower) Policy
The University of Manitoba has been designated a “government body” under the Regulations to The Public Interest Disclosure (Whistleblower Protection) Act. All government bodies are required to implement procedures to manage disclosures, as defined by the Act.
The university’s Safe Disclosure (Whistleblower) Policy was implemented in 2012 to meet the requirements of the Act. The Policy is intended to apply only to the Disclosure of Wrongdoing, as that term is defined in the Act and may be amended from time to time. This Policy is not intended to apply to other types of disclosures, and is not intended as a dispute resolution mechanism to replace grievances, appeal hearings, and other administrative processes. At the time this Policy was approved, the definition of Wrongdoing was:
- An act or omission constituting an offence under an Act of the Legislature or the Parliament of Canada, or a regulation made under an Act
- An act or omission that creates a substantial and specific danger to the life, health or safety of persons, or to the environment, other than a danger that is inherent in the performance of the duties or functions of an employee
- Gross mismanagement, including of public funds or a public asset
- Knowingly directing or counseling a person to commit a wrongdoing described in clauses (a) to (c);
To make a report to the Designated Officer under the Safe Disclosure (Whistleblower) Policy, contact the Office of the Vice-President (Administration) at 204-474-8889 or firstname.lastname@example.org
Responsible Conduct of Research Policy
The university wishes to ensure the highest standards of integrity in all research associated with the institution.
The university’s Responsible Conduct of Research Policy and the Code or Research Ethics were implemented in 2013 to define the institution’s expectations for the responsible conduct of research.
The Responsible Conduct of Research Investigative Procedure details how the University will manage disclosures and investigate allegations under the policy. Breaches as defined under the policy include several examples, one of which pertains to the financial mismanagement of grants or award funds. This includes using grant or award funds for purposes inconsistent with the policies of the funding agencies, misappropriating grant and award funds, contravening a funding agency’s policies, or providing incomplete, inaccurate or false information on documentation for expenditures from grant or award accounts.
To make a report directly to the Designated Officer under the Responsible Conduct of Research Policy, contact the Office of the Vice-President (Research and International) at 204-474-6915 or email@example.com