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Athabasca University

Fraud: Reporting and Responding to Incidents of Fraud or Dishonesty Policy

Department Policy Number

Effective Date

June 17, 2005


Athabasca University is committed to protect the organization, its operations, its employees, and its assets from the consequences of fraudulent activity. The purpose of this policy is to:

  • uphold the University's fiduciary responsibility as a public institution
  • clearly state the University's position with respect to fraud
  • impose a duty on University employees to report a suspicion of fraud as defined by this policy
  • impose a duty on managers, directors, and executive members to detect and protect the university from improprieties
  • protect those who report suspected fraudulent activity
  • ensure a consistent, prompt response to reports of suspected fraudulent activity
  • outline filing and reporting requirements
  • outline consequences for fraudulent activity

This policy applies to all employees of Athabasca University as well as University consultants, contractors, vendors, and partners to the extent that the University resources are involved or impacted and to the extent it is reasonably applicable.

Academic dishonesty will continue to be handled according to the Academic Misconduct Policy. Student nonacademic dishonesty will be handled according to the Non-Academic Misconduct Policy.

Fraud is academic research will continue to be handled according to the Policy on Fraud and Misconduct in Academic Research and Scholarly Activity.


Fraud is "intentional deception resulting in injury to another. Elements of fraud are a false and material misrepresentation made by one who either knows it is falsity or is, ignorant of its truth; the maker's intent that the representation by relied on by the person and in a manner reasonably contemplated; the person's ignorance of the falsity of the representation; the person's rightful or justified reliance; and the proximate injury to the person. Fraud usually consists of a misrepresentation, concealment, or nondisclosure of a material fact, or at least misleading conduct, devices or contrivance." Source: Yogis, John A., Canadian Law Dictionary. (New York: Baron's Educational Services Inc., 2003) p. 114

Fraud includes, but is not limited to:

  • misappropriation, misapplication, destruction, removal, or concealment of University property
  • alteration or falsification of paper or electronic documents (cheques, reference letters, grant applications, time sheets, requisitions, budgets, etc.) including the inappropriate destruction of paper or electronic documents
  • authorizing or receiving payments for goods or services not received or performed
  • altering or deliberately reporting incorrect financial or personal information for either a personal or University advantage
  • unauthorized use of University property and resources for personal advantage or gain
  • any claim for reimbursement of expenses that are not incurred for the benefit of the University
  • bribery, kickbacks, or rebates
  • identity theft
  • misrepresentation of professional or academic credentials or status with the University


Fraud and the concealment of fraud are strictly forbidden at Athabasca University. Such acts will be treated as serious offences and will result in severe discipline up to and including termination if appropriate. Contractors, vendors, and partners who commit fraud will have their contract terminated.

The University is committed to the thorough investigation of all suspected cases of fraud.

The University, to the extent possible, will recover any losses incurred through an act of fraud.

All employees have an obligation to report any suspected fraud. Failure to do so may result in discipline.

All managers, directors, and executive members must be familiar with the types of improprieties that may occur in their area; develop and enforce internal controls and policies that will provide the security and accountability of the resources entrusted to them; and report any indication that an act of fraud is occurring or has occurred in their area.

All employees involved in an investigation of suspected fraud will retain the rights, privileges, and protection afforded to them through the applicable University policies and collective agreements in effect at the time. This Fraud Policy is intended to be applied in concert with existing policies, practices and collective agreements governing misconduct and discipline.

An individual who in good faith reports a suspicion of fraud will be protected from retaliation by employees of the University. Under no circumstances will this individual be threatened, intimidated, or dismissed because he or she acted in accordance with this policy. In addition, every effort shall be taken to mitigate any consequences of the process for other individuals who may unintentionally be adversely affected by it.

An individual who makes allegations of fraud, which are proven to be made in bad faith, will be disciplined.

Unlawful acts may be reported to the applicable law enforcement agency.




Duty to Report

All suspected instances of fraud must be reported promptly either to the immediate supervisor or the Associate Director, Risk Management. It is the responsibility of the supervisor to notify the Associate Director, Risk Management. Any allegations must not be discussed with anyone else without prior notification and permission of the Associate Director, Risk Management.




Appropriate university managers and the Associate Director, Risk Management will determine the necessary action depending upon the nature of the allegations. The Associate Director, Risk Management may obtain legal advice and/or an external fraud advisor prior to composing the investigation group and will halt the investigation at any time if the allegation(s) does not constitute fraud. The matter may in such cases be referred to the supervisor or the Director, Human Resources if it is not fraud but another behavioural concern.


The composition of the investigative group is identified below. No persons other than those assigned by the Associate Director, Risk Management or a law agency, will conduct investigations or interviews.

  • The Director, Human Resources if an employee(s) is involved;
  • The contract manager if a contractor is involved;
  • The Vice-President, Academic if an educational partner is involved;
  • Law enforcement agents, in instances where criminal charges may be warranted;
  • The University solicitor and/or an external fraud advisor; and
  • The Director, Financial Services and/or the Director, Computing Services, depending on the nature of the fraud allegation.


Any individual suspected of fraudulent activity should not be confronted prior to commencement of the investigation process. Records related to the activity may need to be seized before the suspected individual(s) becomes aware of any investigation. The investigative group will have free and unrestricted access to all university records and premises and the authority to examine, copy, and/or remove all or any portion of the contents of computer and paper files, desks, cabinets and other storage facilities on university premises without prior knowledge or consent of any individual who may use or have custody of any such items or facilities, when it is within the scope of their investigation.


The purpose of the investigation and the reporting of appropriately documented fraudulent activities are to provide a sound foundation for the protection of the innocent, the removal or discipline of the wrongdoers, appropriate judicial action when warranted by the facts, and the basis for filing fidelity bond claims and civil litigation seeking recovery. If fraud has occurred the university insurer must be notified immediately.


If, in the opinion of the investigating team, fraud is probable and after receiving positive confirmation from law agencies, if applicable, and the university solicitor and/or an external fraud advisor, the Associate Director, Risk Management will advise the respondent about the complaint and its particulars and invite the respondent to respond to the evidence either orally or in writing before any decision is made by the investigating group. If the respondent is an employee, the applicable union representative will be in attendance.


Employees suspected of fraud may be suspended with pay pending completion of the investigation.



All information collected or received by the investigation group will remain confidential except as would be necessary for a thorough investigation and/or as required by law.


Assistance to Law Enforcement and Regulatory Agencies

The Associate Director, Risk Management is the only authority authorized to provide assistance to law enforcement or regulatory agencies. All requests for assistance from such agencies shall be immediately forwarded to the Associate Director, Risk Management for determination and handling.




Upon completion of the investigation, the investigative group will submit a final report to the President, the appropriate Vice-President, and the Vice-President, Finance and Administration.


Employees who commit an act of fraud will be subject to disciplinary actions which may include termination. Contractors, vendors, and partners who commit fraud will have their contract terminated.


Failure by employees to report suspected fraud may result in discipline.


Filing and Reporting


If an individual is proven to have committed fraud, information relating to the offence will be placed on the appropriate file (i.e., personnel, contract). The retention of such records will be governed by established records policies and applicable collective agreements.


The Associate Director, Risk Management will make recommendations for improvements to internal controls that are identified as a result of each fraud investigation and submit this report to the Vice-President, Finance and Administration.

Approved by

Athabasca University Governing Council, Motion # 150-4, June 17, 2005

Amended Date/Motion No.

Related References, Policies, and Procedures

Policy on Fraud and Misconduct in Academic Research and Scholarly Activity
Information Technology Electronic Data Security Policy
Athabasca University Protection of Privacy Policy

Academic Misconduct Policy
Non-Academic Misconduct Policy

Applicable Legislation/Regulation

AUFA Terms and Conditions
CUPE Collective Agreement
AUPE Collective Agreement
FOIP Legislation

Responsible Position/Department

This policy is maintained and administered by the Office of the Vice-President, Finance and Administration. For further information , please contact the Associate Director, Risk Management.



Office of the President, July 2005

Updated May 06 2014 by Advancement Web Services

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