The UBC community is invited to comment on the proposed amendments to the Financial Investigations Policy (SC15) (the “Policy”).
The Internal Audit Policy was first approved in 1977 and last substantively revised in 2014, when the Internal Audit Policy was amalgamated with the Whistleblower Policy to create the Internal Audit, Investigations, and Financial Whistleblower Policy (SC15).
A Policy Development Committee (the “Committee”) has been convened to develop proposed amendments and has prepared a draft proposal. The primary objectives of the proposed amendments are to align the Policy with best practices and ensure consistency with other Board of Governors’ policies.
More specifically, the Committee’s most notable proposed amendments to the Policy are:
- Scope Expansion: The proposed Policy broadens the scope to include not just UBC employees and students but also volunteers, service providers, contractors, and those with emeritus status. The scope has been broadened to capture anyone who can affect money, assets, or resources that belong to UBC or that are administered by UBC on behalf of third parties.
- Internal Assurance Charter: The Internal Assurance Charter was approved by the Board of Governors in March 2024 and the proposed Policy is aligned with and incorporates references to the Internal Assurance Charter.
- Definition and Evaluation of Financial Misconduct: The proposed Policy introduces the “reasonable person test” to assess Financial Misconduct. This test considers what a reasonable person would have understood in similar circumstances, recognizing the fine line between incompetence, carelessness, and negligence, on the one hand, and intentional misconduct on the other. The degree of intent may be considered as a factor when determining consequences.
- Investigative Authority: The proposed Policy grants Internal Assurance more explicit powers to conduct investigations, with authority to access all relevant UBC records and authority to interview UBC Members. If an investigation is required, Internal Assurance will conduct the investigation, unless the CARO and the relevant Administrative Head of Unit agree that the Administrative Head of Unit will conduct the investigation. The Investigator will collaborate with relevant UBC units, such as Human Resources, the Office of the University Counsel, and Safety and Risk Services, and those units will provide advice and support as appropriate.
- Creation of Rules: The proposed Policy allows the Responsible Executive to issue and maintain Rules to regulate the prevention and detection of Financial Misconduct. The Responsible Executive must establish an advisory committee and solicit public feedback before finalizing any Rules. Internal Assurance is responsible for monitoring compliance with the Rules and reporting back to the Audit Committee.
- Post-Investigation Process and Internal Controls: The proposed Policy makes it explicit that Internal Assurance may issue recommendations following investigations, including recommendations for remediation measures and steps to improve internal controls. This creates a formal post-investigation follow-up process aimed at preventing future instances of misconduct.
For further information about the proposed amendments, please see the information package that was provided to the Board of Governors at: https://bog3.sites.olt.ubc.ca/files/2024/11/3_2024_11_Proposed-Amendments-to-Financial-Investigations-Policy-SC15.pdf
The proposed amendments are now being published and all members of UBC’s community are encouraged to provide their comments. Please submit feedback to the Office of the University Counsel at university.counsel@ubc.ca by February 19, 2025.
Feedback received by the Office of the University Counsel from the UBC community will be provided to the members of the Committee for review and consideration. The Committee does not provide individual responses to persons submitting feedback. However, the feedback received will be summarized, along with the Committee’s response, in a Community Consultation Summary that will be included in the submission materials that are generally shared in open sessions of meetings of the responsible Board committee and the Board of Governors.