​Fraud Deterrance ​Definitions


When used in the Foundation’s Fraud Deterrence Program policies, guidelines and
supporting procedures, these terms are to be interpreted as follows:


Complainant
An individual who has disclosed or reported an alleged fraudulent or unethical activity,
irregularity or other wrongdoing.

Ethical Conduct
Conduct that is fair, free from deception and impropriety, and is consistent with the standards identified in the Foundation’s Policies and Procedures. 

Foundation
The Waskesiu Foundation Inc., under the governance of the Foundation’s Board of Directors.

Fraud
An intentional misappropriation of assets, including physical and monetary assets and
information technology (e.g. software, intellectual property, data), through concealment and/or deception, including manipulation of Foundation records. A false representation of a matter of fact, whether by words or by conduct, by false or misleading allegations, or by concealment of
what should have been disclosed ‐ an intentional act that is committed to secure an unfair or unlawful gain, and includes but is not limited to:

  •  Misappropriation of Foundation property.
  •  Altering or deliberately recording incorrect information (financial or non‐financial) for either a personal, related party, or Foundation advantage.
  •  Unauthorized use of Foundation property and resources for personal advantage or gain.
  •  Any claim for reimbursement of expenses that are not incurred for the benefit of the Foundation.
  •  Bribery.
  •  Identity theft.
  •  Forgery or alteration of documents.
  •  Authorizing or receiving payment for goods or services not received or performed.
  •  Misrepresentation of professional credentials or status with the Foundation.

Good Faith
A sincere and honest belief, without any malice or the desire to defraud or deceive others.


Impropriety
Failure to observe generally accepted standards or to display honesty and integrity. 

Irregularity or Wrongdoing

  • Any activity or potential activity that willfully violates Foundation policies, regulations or​ procedures, including questionable accounting or auditing matters within the Foundation, including but not limited to:
  • A contravention or breach of Foundation Policies or Regulations.
  • Activities that violate local, provincial or federal laws.
  • Breach of confidentiality.
  • Misuse of Foundation funds, assets, or resources.
  • Gross mismanagement.
  • A deliberate act or omission that creates danger to the life, health or safety of persons or to the environment.
  • Unauthorized interference in an action, activity, process, transaction, or event.
  • Reprisals for reporting an alleged incident.
  • Discrimination, harassment, physical assault or bullying.
  • Vandalism.
  • Harmful misrepresentation of information or data. 


Members of the Foundation Community (Foundation Member(s))
The Foundation’s Board of Directors, administrative personnel, volunteers, and any other person or organization while acting on behalf of or at the request of the Foundation, including, but not limited to, persons giving advice or providing services to the Foundation at the request of the Foundation, and anyone involved in a decision‐making process on behalf of the Foundation.

Reprisal
The act or an instance of retaliation in any form, including but not limited to:

  •  Dismissal or threat of dismissal.
  •  Disciplinary action.
  •  Intimidation, coercion, or threats.
  •  Imposition of any penalty.
  •  Harassment.
  •  Discrimination.

Respondent
An individual who is the subject of a report of alleged fraudulent or unethical activity,
irregularity or other wrongdoing.

Retaliation
Any adverse reaction or action taken against an individual as a direct consequence and response to the individual having made a good faith report of a possible fraud, irregularity, wrongdoing or violation of the Foundation’s policies. 

Unethical Behavior
Any behavior that is deliberately deceptive, unfair, dishonest, lacking integrity, or a violation of the standards identified in the Foundation’s Policies and Procedures. Unethical behavior may not necessarily be illegal. 

Whistleblower
An individual or entity who files a report of suspected illegal or unethical conduct that is
believed, in good faith, to be a violation of law or the Foundation’s policies.


Fraud Deterrence Policy

​Purpose
The Waskesiu Foundation Inc. (‘the Foundation’) recognizes the importance of protecting the organization, its operations, assets and reputation from the consequences of fraudulent activity.

The purpose of this Policy is to:

  • Clearly state the Foundation’s position with respect to fraud, irregularities and other wrongdoing.
  • Foster an environment that promotes fraud awareness.
  • Facilitate and support the development of controls to aid in the prevention and detection of fraud.
  • Confirm the shared responsibility of all Foundation members to report suspicions of fraud or irregularity or other wrongdoing as defined by this Policy.
  • Articulate the process to be followed in responding to reports of alleged fraudulent activity.
  • Evaluate the risk of fraud and implement best practices in processes, procedures and controls that are necessary to mitigate the identified risks, and reduce the opportunities for fraud.
  • Develop an effective and appropriate oversight process.

Principles
This Policy is founded on, and embodies, the following guiding principle:

  • Create and maintain a culture of honesty, integrity, accountability and ethical behavior.

Scope
This Policy applies to all Foundation members, including the Board of Directors, administrative personnel, and all individuals and parties acting on behalf of the Foundation. 

The scope of this Policy is limited to activities related to, or funds or property owned by, or in the care of, the Foundation.  Allegations or identification of acts other than fraud, are outside the scope of this Policy, and will be resolved with reference to the appropriate Foundation policies, regulations, guidelines or legislation.

Any investigation process required will be carried out without regard to the alleged wrongdoer’s length of service, position/title, or relationship to the Foundation.

Policy
The Foundation, as represented by the Board of Directors and administrative personnel, is committed to maintaining the highest standards of honesty, integrity and ethical conduct.  Fraud, or the concealment of fraud, will not be tolerated.

Foundation members who are found to have committed an act of fraud or other impropriety will be subject to disciplinary action up to and including termination from their association with the Foundation, and legal prosecution if appropriate.

The Foundation, to the extent reasonably possible, will recover any losses incurred through fraud or financial improprieties.

All Foundation members have an obligation to report suspected fraud, irregularities or wrongdoing.

Foundation members will adhere to the principles of ethical conduct and reporting of wrongdoing.

All Foundation members involved in an investigation of alleged fraud or irregularity will retain and be accorded the rights, privileges and protections provided to them through the applicable legislation, Foundation policies and agreements in effect at the time the alleged fraud or irregularity was committed.

Responsibilities
The Foundation, as represented by the Board of Directors and administrative personnel, is responsible for: setting the appropriate ‘tone at the top’; establishing effective controls and procedures to prevent and detect fraud, irregularities and other wrongdoing; and maintaining an effective oversight process to safeguard the Foundation’s assets and resources.

The Foundation’s Treasurer and external auditors are responsible for providing objective assurance to the Board of Directors that effective and sufficient controls are in place for the identified fraud risks.

The Foundation’s Board of Directors is responsible for the appointment of  competent and qualified individuals who will have primary responsibility for the investigation of suspected fraudulent acts covered by this Policy.

Foundation members must not tolerate any fraudulent activity, irregularities or unethical activities.

Foundation members are expected to consistently demonstrate and promote professional conduct, ethical behavior, and integrity by complying with all applicable Foundation policies and procedures, laws, rules, regulations and applicable professional codes of conduct.

Procedures
Any Foundation member who suspects any irregularity, wrongdoing or fraudulent activity is to immediately report it to the Foundation’s Board of Directors, and cooperate fully when requested in all resulting investigations.

All reported allegations of fraudulent activity, irregularities or wrongdoing will be responded to and investigated in accordance with the processes and procedures identified in the Foundation’s Fraud Deterrence Operating and Investigation Guidelines.

Non-Compliance
The Foundation expects that its members will comply fully with this Policy, including all requirements for disclosure.  Failure to do so may constitute grounds for disciplinary action in accordance with any applicable agreement, contract, legislation or other applicable disciplinary process.

Confidentiality

All Foundation members involved in an investigation of fraud, irregularity or wrongdoing must keep the details and results of the investigation confidential, in order to safeguard and protect the rights of those involved in the allegations, and preserve the legal validity of all evidence collected.

The Foundation will protect the confidentiality of individuals and events under investigation, except where disclosure is required by law.  The details and particulars of any investigation will not be disclosed or discussed with any individuals or parties other than those deemed necessary for investigation purposes, or as required by law.

Following an investigation, if a Foundation member, or any other individual, is determined to have committed fraud, an irregularity, or other wrongdoing, this information can be disclosed to the extent allowable by law.


Fraud Deterrence Operating and Investigation Guidelines


A.    Operating Guidelines


Reporting of Alleged Illegal or Unethical Behavior 

· Foundation members are expected to report any known or suspected instances of

    1. illegal or unethical behavior.
    2.  Violations of Foundation Policies, applicable laws, rules or regulations.

·   Reports should be directed to a member of the Foundation’s Executive Committee (Chair, Vice-Chair or Treasurer).  If, for any reason, an individual is not comfortable reporting the matter to a member of the Foundation’s Executive Committee, they may submit their report to any member of the Foundation’s Board of Directors.

· If a Foundation member wishes to report a matter confidentially or anonymously, they may submit their report by mail to Foundation at PO Box 242, Saskatoon, SK. S7K 3K4.

·  All reports of alleged wrongdoing should include the following information:
     1.       A description of the alleged wrongdoing.
     2.      The name(s) of the individual(s) alleged to have committed the wrongdoing.
     3.      The date(s) of the alleged wrongdoing.
     4.      The details, and any supporting documentation, of any related reports that have been previously made to Foundation personnel, or other external individual or entity.
     5.      Any evidence or documentation supporting the alleged wrongdoing.
     6.      Any other available information that is relevant to the assessment of the allegations. 

Confidentiality, Impartiality and Protection from Reprisal
·  The Foundation will ensure that all individuals who make reports in good faith are not subjected to any form of retaliation.  The Foundation will investigate and take appropriate action as warranted, to address all allegations of reprisal.  However, any individual who is found to have made malicious or bad faith allegations/reports may be subject to appropriate disciplinary and legal action.  When requested, members of the Foundation community are expected to cooperate in all investigations of alleged wrongdoing.

·  Any person that believes that he or she has been subject to reprisal as a direct result of reporting an alleged wrongdoing to the Foundation, should immediately provide documented details through the reporting channels identified above.  The Foundation will insure that all allegations of reprisal are investigated and, if justified, that appropriate corrective action is taken, in accordance with Foundation procedures and protocols.

·  The Foundation will take all necessary and appropriate action to carefully and fairly review, investigate and respond to reports of alleged wrongdoing.

·  Any individuals involved in allegations of wrongdoing will be treated fairly and impartially, and will maintain all rights, privileges and protections that are afforded to them under legislation, agreements, and Foundation policies in effect at the time of the alleged wrongdoing. 

Receipt, Review and Recording of Disclosure
·  All allegation reports received by the Foundation will be reviewed, recorded in a secure internal database, and forwarded to the appropriate appointed individuals, within 10 days of receipt, for further review and investigation, according to established Foundation policies and procedures.

·  The Foundation’s Treasurer will maintain all  allegation reports in a secure electronic database.  Each report will receive a unique reference number so that a follow-up can be entered as received.  The following information will be recorded for each allegation report received: Date that the report was received by the Foundation, description of the report allegations, name of the reporting individual (if provided), current status of the report (resolved, under investigation, dismissed, withdrawn, or pending/no action), and actions taken (date and comments).  This internal database will support the Foundation’s ability to effectively manage and oversee the corresponding investigation and resolution processes.

·  All reports of alleged wrongdoing will be dealt with in accordance with existing Foundation policies, procedures and processes.

Reporting to the Foundation’s Board of Directors
·  At the end of each fiscal year, the Foundation’s Treasurer will provide the Foundation’s Board of Directors with a written report that includes the following:
     1.       The number of reports of alleged wrongdoing that were received during the fiscal year.
     2.      The number of reports that were investigated.
     3.      The findings of any corresponding investigations.
     4.      Any actions taken as a result of the investigation’s findings, and the corresponding results. 

This report will respect the privacy of all individuals involved in the reported incidents. 

Management of Safe Disclosure Report Information
·         All applicable report data and information will be managed and retained in accordance with the applicable Foundation policies, procedures and guidelines. 

B.    Investigation Guidelines
 

Introduction
·  There will be timely and professional responses to all disclosure reports received, which are believed to have been made in good faith, and to any resulting subsequent investigations.
·  Responsibilities will be clearly assigned for the initial review and evaluation of the disclosure report, subsequent investigation of the allegations where appropriate, determination of whether or not wrongdoing has occurred, recommendations for corrective actions and measures where wrongdoing is determined, and reporting the outcomes/results of investigations in accordance with established protocols.
·  The Foundation’s Fraud Deterrence Policy, and related guidelines and procedures are intended to enhance and support other Foundation policies, guidelines and procedures.

 Principles
·  Investigations will be conducted in accordance with the principles of natural justice and due process, consistent with existing Foundation policies.
·  All Foundation members have the opportunity to disclose evidence of wrongdoing or other irregularity without fear of reprisal.
·  Confidentiality, privacy, discretion, sensitivity, fairness and impartiality will be maintained throughout the investigation process, to the fullest possible extent.

Responsibilities
·  The Foundation’s Board of Directors has a responsibility to take prompt, effective action to address all reported allegations of wrongdoing.

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