Fraud Prevention and Whistleblower Policy

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Preamble

WoodGreen believes in conducting its business affairs according to high ethical standards and has embodied these beliefs in the Code of Conduct policy which, among other things, requires employees to conduct themselves honestly and ethically and in the best interests of WoodGreen, to protect WoodGreen’s assets and its reputation, and to enhance accountability for the management of donated and public funds.

Management is accountable to the Board of Directors for putting in place internal controls which are designed to guard against fraud. However, fraud may involve collusion or the involvement of individuals and organizations outside of WoodGreen, so internal controls may not always be effective in doing so.

This policy is intended to provide WoodGreen staff members, clients, and other stakeholders (contractors, volunteers, and other organizations) with a safe mechanism for reporting incidents where WoodGreen employees may be engaging in activities prohibited by this policy.

For staff members, this policy supplements the Staff Complaints Policy, the Code of Conduct, and the ongoing relationship between a staff member and his/her supervisor. Staff members who have reason to believe that an acitviity prohibited by this policy has occurred may use any of these arrangements to bring an issue forward for investigation.

For WoodGreen clients, this policy supplements the Client Complaint Policy. Clients who have reason to believe that an activity prohibited by this policy has occurred may use either policy to bring an issue forward for investigation.

In deciding whether to report an incident under this policy, rather than using one of the other policies noted above, staff and clients may wish to use the other policies for possible minor infractions and use this policy for more serious ones.

Policy

WoodGreen employees shall not commit fraud or use WoodGreen assets or their position in WoodGreen for personal benefit for the personal benefit of others, or for purposes unrelated to WoodGreen’s business.

Examples of prohibited activities are:

• stealing WoodGreen property, including supplies, software, and WoodGreen records,

• extortion of WoodGreen staff, clients, or vendors,

• misappropriation of WoodGreen funds,

• forgery or alteration of cheques, securities records, or other similar instruments,

• obtaining WoodGreen funds dishonestly by falsifying accounts or other records (including expense claims and time sheets),

• profiteering as a result of insider knowledge of WoodGreen activities,

• a violation of WoodGreen’s procurement policies or procedures,

• exercising authority or influence over a matter where a conflict of interest exists as described in the Code of Conduct policy,

• acts of bribery, including the acceptance of commissions or accepting anything of material value from vendors, clients, tenants, or others doing business with WoodGreen,

• intentionally destroying or impairing WoodGreen assets,

• disclosing confidential information to outside parties, and

• conspiracy to commit fraud with others.

Employees who suspect that fraud or other activities prohibited by this policy may have taken place are required to follow the procedures outlined below to report the incident. Failure to do so may be a violation of the Code of Conduct.

Employees who act in good faith to report suspected fraud or other activities prohibited by this policy will not be discharged, demoted, suspended, threatened, harassed, or discriminated against in any manner for doing so. However, in view of the serious nature of this policy, employees who use this policy maliciously to impugn the reputation of other employees when they have no reason to believe that misconduct has occurred may be subject to discipline.

Procedures

Employees who suspect that an activity prohibited by this policy may have take place are required to report the incident using the Whistleblower Reporting Form located on WoodGreen website. Vendors, clients, tenants, and other parties external to WoodGreen may also report incidents using this form.

When a whistleblower incident is submitted, the report is sent to the President. (See information below)

Once received, the President will determine an investigation protocol which is appropriate to the nature of the incident and the individuals involved.

A report summarizing the findings of the investigation will be submitted to the President by the investigating officials. A summary of the investigation and any resulting action will be reported to the board of directors through the annual risk management report. A summary of the investigation will be reported to the whistleblower, except for any matters which are protected by confidentiality, such as employee discipline.

Whistleblowers may submit anonymously if they wish. However, in such cases, the findings of the investigation cannot be communicated to the whistleblower.

Each whistleblower incident will treated with confidentiality and due care.

Training Plan

This policy shall be announced to directors and managers in management meetings and subsequently to staff in unit meetings.

This policy shall be included in the onboarding process for new staff.

Communication Process

This policy shall be communicated to employees together with the Code of Conduct policy and shall be posted with other WoodGreen operating policies.

This policy and the reporting procedures shall be posted on the WoodGreen website.

Forms

Whistleblower Reporting Form

When completed, submit online at via Dropbox at https://www.dropbox.com/request/zhP9EA8Q7uXbwaO7S5mB
(Dropbox will ask for your e-mail address. If you wish to remain anonymous, enter something that looks like an e-mail address.)

or mail form to:

Office of the President
WoodGreen Community Services
Suite 100, 815 Danforth Avenue
Toronto, Ontario
M4J 1L2