Financial Irregularities Response Management (FIRM)
UVic administers large volumes of funds and other assets for teaching, research, operations and other related purposes.
Financial Irregularities Response Management (FIRM) provides guidance on how UVic will respond to the suspicion or detection of Financial Irregularities (FI), while protecting the interests of the entire university community. This includes people who make good-faith disclosures and safeguards individuals if disclosures prove unfounded.
If you suspect that a financial irregularity exists or has taken place, it’s easy to make a report. The report will be investigated objectively, quickly and as confidentially as possible – with anonymous reporting available.
What is a financial irregularity?
A financial irregularity (FI) represents a departure from standard UVic procedures, policies or laws that involve funds or other assets. FI are not inherently illegal, but they may be, depending on the circumstances. FI can be unintentional or intentional.
Anyone can perpetrate intentional FI against UVic, and almost any aspect of UVic can be affected. Examples of intentional FI include:
- misappropriation, misapplication or theft of UVic’s funds, securities, supplies, inventory, fixtures or equipment, trade secrets and intellectual property or services
- any breach of a finance‐related fiduciary duty or obligation of confidentiality
- forgery, falsification or alteration of any finance‐related documents or records (cheques, bank drafts, promissory notes, work/employment records, travel expense reports, contractor agreements, purchase orders, electronic files, etc.)
- deviations from or violations of standards contained in UVic’s policies and procedures in the handling or reporting of money, cash equivalents or financial transactions
- deviations from or violations of standards contained in UVic’s purchasing or supply management procedures and requirements
- giving or receiving any form of unauthorized benefit, including bribery, kickbacks or commissions
- concealing or abetting any of the above activities
Reporting financial irregularities
Financial irregularities should be reported within 10 business days if possible, but anyone is encouraged to report suspicions of FI as soon as possible.
UVic will not tolerate any acts of retaliation against anyone who discloses an allegation of FI. If you are subject to any act of retaliation, please report your concerns to your supervisor or area lead or, if that option is not appropriate, you can also report your concerns confidentially to Internal Audit at internalaudit@uvic.ca or 250-853-3123.
UVic also provides an anonymous reporting option via the UVic Safe Disclosure Reporting Mechanism, for suspected FI. Please note that the response to an anonymous statement may be limited if Internal Audit cannot follow up with you.
Response to suspected FI
UVic’s response to suspected FI has three stages:
- Identification and reporting
- Investigation
- Resolution
Our response to allegations of FI needs a number of different teams. These teams have specific roles and bring different skills and strengths. All teams collaborate to provide an efficient and effective response mechanism. FI is investigated objectively, quickly and as confidentially as possible.
All reports of FI will be promptly brought to the attention of Internal Audit. Internal Audit will consult with other appropriate departments as necessary. These could include Human Resources, Faculty Relations and/or General Counsel. This consultation will take place at the beginning of the investigation. If appropriate, it will continue throughout the investigation.
UVic will act in compliance with the Freedom of Information and Protection of Privacy Act (FIPPA) and with any relevant UVic policies.
For more information about the FI process, please review the Financial Irregularities Response Management document.
Principles and priorities
To guide UVic’s response to potential occurrences of intentional FI, UVic holds the following principles:
- UVic takes allegations of FI seriously
- UVic values all people who make good-faith disclosures
- UVic has an obligation to protect the reputation of individuals alleged to have committed intentional FI until allegations are proven
- UVic has a responsibility for professional conduct in dealing with allegations of FI and any resulting investigation
FI response priorities are to:
- Safeguard and protect the university from any losses
- Protect disclosers from potential acts of reprisal
- Protect the reputation of individuals investigated until allegations are proven
- Protect the reputation of the university
Response actions may vary depending on the nature and extent of the suspected FI. However, every report of FI is taken seriously. Every report follows a formal, confidential review and response process. Investigation information is only shared on a strict need-to-know basis.