We're committed to maintaining the highest standards of honesty, integrity and ethical conduct. Our volunteer Board of Directors have board policies in place which demonstrate this commitment. These policies are backed by controls, processes and procedures. Together they support our Core Value of Responsible Stewardship, and maintain a reputation for the highest standards of trust & confidence in serving the interests of all donors & stakeholders.
We have guidelines for conduct required of all of our directors and officers to assist them to fulfill their statutory and fiduciary obligations and maintain a reputation for the highest standards of trust and confidence in serving the interests of all donors and stakeholders.
Directors and officers are required to use the utmost good faith in all their dealings involving the Foundation. Directors must exercise their powers in a genuine manner, in the best interests of the Foundation, and not for any side purpose, special interest or other agenda.
We recognize the importance of protecting our organization, operations, assets and reputation from the consequences of fraudulent activity. Our goal is to maintain a culture of honesty, integrity, accountability and ethical behaviour.
Financial controls are the procedures, policies, and means by which we monitor and control the direction, allocation, and usage of our financial resources. Controls are in place involving the segregation of duties, proper authorization, documentation & more.
This policy (this “Policy”) is intended to establish guidelines for conduct required of all directors and officers of The Waskesiu Foundation Inc. (the “Foundation”). The objective is to assist directors and officers of the Foundation to more effectively fulfill their statutory and fiduciary obligations and maintain a reputation for the highest standards of trust and confidence in serving the interests of all Foundation donors and stakeholders.
The following guidelines are not intended to be exhaustive. If issues outside the explicit guidelines arise, they should be addressed in accordance with the general principles in this document or through the exercise of sound business and ethical judgment. These guidelines are supplementary to any statutory or common law duties and obligations, or any other standards of conduct applicable to directors and officers of the Foundation.
As a director and/or officer of the Foundation, I agree to the following principles and responsibilities governing my conduct:
I acknowledge that:
(i) act honestly and in good faith with a view to the best interests of the Foundation;
(ii) exercise a degree of care, diligence and skill that a reasonable person would exercise in comparable circumstances; and
(iii) promptly disclose any interests in material contracts or proposed material contracts, or any other actual or potential conflict of interest, in accordance with the Foundation’s Conflict of Interest Policy, as the same may be adopted and/or amended from time to time by the Board.
At all times, I will, subject to the provisions of applicable law, respect the confidentiality of sensitive or other confidential information acquired in the course of my duties, whether as a director or as an officer of the Foundation. In addition, I will at all times observe the provisions of applicable law protecting the privacy of personal information about individuals
I specifically agree to adhere to and advocate the following principles and responsibilities governing my conduct as a director or officer of the Foundation:
I understand that I will be individually accountable to the Foundation for adherence to the requirements of this Code of Conduct
Directors and officers of The Waskesiu Foundation Inc. (the “Foundation”) are required to use the utmost good faith in all their dealings involving the Foundation. Directors must exercise their powers in a bona fide manner, in the best interests of the Foundation, and not for any side purpose, special interest or other agenda.
The objective of this policy (this “Policy”) is to assist directors and officers of the Foundation to more effectively fulfill their statutory and fiduciary obligations to the Foundation. This Policy applies to all Office Holders (as that term is defined below) and is supplementary to any statutory or common law duties and obligations, or any other standards of conduct, applicable to Office Holders.
In this Policy, the following terms shall have the following meaning:
For the purposes of this Policy, “private interest” means any material financial or other advantage or benefit to an Office Holder, to a member of his or her family, or to an associate which might reasonably be perceived by a well informed observer as capable of compromising the fair and impartial making of a decision or the carrying out of a duty or function on the basis of considerations properly related to that decision, duty or function, and for greater certainty includes any material, actual or promised:
A “private interest” does not include an interest arising from the exercise of an official power or the performance of an official duty or function that:
Potential Conflicts of Interest
An Office Holder must, upon being appointed, provide the Secretary of the Foundation with a declaration of all private interests they are aware of that could reasonably have potential to give rise to a conflict of interest for them. Each Office Holder will have an obligation to update his/her declaration from time to time as necessary to keep it current and comprehensive.
An Office Holder must not carry out or participate in the carrying out of a duty or function, including the making of any decision, if he or she has a conflict of interest. In addition, an Office Holder must not use his or her office to seek to influence a decision, to be made by another person, to further the Office Holder’s private interest.
Insider Information and Use of Assets
An Office Holder shall not knowingly use information that is obtained in the course of carrying out his or her duties that is not generally available to members of the Foundation to further or seek to further his or her private interest. In addition, an Office Holder shall not knowingly disclose information to any individual or organization that could provide an advantage not generally available to other individuals or organizations that may be in competition with the recipient of the information.
An Office Holder shall not use assets owned, controlled or provided by the Foundation, as the case may be, (including but not limited to equipment, office space, or materials) to further his or her private interest, or otherwise except for approved purposes.
Accepting Extra Benefits
An Office Holder must not accept a fee, loan, gift or any other private benefit of any kind that is connected directly or indirectly with the performance of his or her duties as such, except:
If the value of a gift or private benefit referred to in the exceptions above exceeds $200 in value, or if the total value received directly or indirectly from one source in any 12 month period exceeds $300, the Office Holder must immediately disclose particulars of the gift or benefit in writing to the Board indicating:
Procedure on Conflict of Interest
Disclosure by Office Holder
An Office Holder who has reasonable grounds to believe he or she has a conflict of interest must immediately:
If an Office Holder breaches this Policy and the Office Holder, or his or her family member or associate thereby realizes any financial gain, the Office Holder shall on demand pay the amount so gained to the Foundation, together with all reasonable legal and accounting fees and disbursements and other costs incurred by the Foundation to investigate and enforce such claim.
On the request of the relevant Office Holder, the Board shall be entitled to conclusively determine:
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:
This Policy is founded on, and embodies, the following guiding principle:
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.
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.
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.
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.
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.
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.
A. Operating Guidelines
Reporting of Alleged Illegal or Unethical Behavior
Foundation members are expected to report any known or suspected instances of:
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:
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:
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
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.
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.
The Foundation’s Board of Directors has a responsibility to take prompt, effective action to address all reported allegations of wrongdoing.
When used in the Foundation's Fraud Deterrence Program policies, guidelines and supporting procedures, these terms are to be interpreted as follows:
An individual who has disclosed or reported an alleged fraudulent or unethical activity, irregularity or other wrongdoing.
Conduct that is fair, free from deception and impropriety, and is consistent with the standards identified in the Foundation’s Policies and Procedures.
The Waskesiu Foundation Inc., under the governance of the Foundation’s Board of Directors.
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:
A sincere and honest belief, without any malice or the desire to defraud or deceive others.
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:
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.
The act or an instance of retaliation in any form, including but not limited to:
An individual who is the subject of a report of alleged fraudulent or unethical activity, irregularity or other wrongdoing.
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.
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.
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.
Our financial control processes fall under the following specific key control activities:
Segregation of Duties:
Proper Authorization of Transactions and Activities:
Adequate Documents and Records:
Physical Control Over Assets and Records:
Board and Independent Financial Oversight: