Fraud

Our priority is to safeguard the City's assets, funds and information from fraudulent activity. The Fraud policy allows any member of the public or City employee to allege fraud against Council, staff, contractors, and members of the public if they have reasonable grounds to believe it has occurred. If you have a concern about possible fraudulent activity at the City of St. John's, contact us.

What is “fraud”?

Fraud is a deliberate act to get property, money, security or any service from the City by means of deceit or falsehood. It includes:

• falsifying records or documents
• unauthorized use of City resources
• failing to declare a conflict of interest
• theft or misappropriation of City funds or property
• collusion with vendors
• intending to deceive by suppressing the truth or suggesting something is false
• misrepresentation of information

Fraud does not include:

• unintentional acts of negligence
• poor performance by employees or contractors.

Who can make an allegation of fraud?

Any member of the public or employee of the City of St. John's can make an allegation of fraud.

Allegations can be confidential, but the more detail provided, the better. Allegations should also be timely, so that investigating it serves a useful purpose. There should be a reasonable prospect of the allegation being substantiated.

Confidentiality is an important principle. While an allegation can be made anonymously the identity of those involved in an investigation (including the identity of the person alleging fraud and the identity of the person alleged to have committed fraud) will be protected to the fullest extent possible.

Employees who reasonably believe that fraud has occurred have a duty to notify their manager, a member of Executive or the Office of the City Internal Auditor. Any employee who knowingly makes a false or bad faith allegation will be subject to disciplinary action.

Fraud Hotline

Do you have reasonable grounds to believe fraud has occurred? Do you have a concern about possible fraudulent activity at the City of St. John’s? If so contact the fraud hotline. We are only only able to act if the fraudulent activity is related to municipal resources, property, or services. If you need to report theft of personal items, scams, or income support allegations, contact the appropriate authority. For details, contact the Royal Newfoundland Constabulary or the provincial government.

Fraud investigations

The Office of the City Internal Auditor investigates allegations. They use best practice approaches to conduct investigations. When an allegation involves an employee, the Department of Human Resources and the City Solicitor are involved. They may decide to refer the investigation to the Royal Newfoundland Constabulary or other regulatory agencies.

Step one is to take immediate action. Our goal is to prevent theft, alteration or destruction of relevant evidence, including any records. The City Internal Auditor tells the appropriate managers and/ or departments of the investigation to assist in securing any evidence. They may also involve the Manager of Corporate Risk and Recovery.

Depending on the allegation, the City Internal Auditor may delegate the appropriate departmental manager to investigate and report on the status and outcome of their investigation.

A person suspected of fraudulent activity may not be confronted at the start of an investigation. Those alleged to have committed fraud will be provided an opportunity to respond.

At the conclusion of the investigation, the City Internal Auditor will provide the City Manager with recommendations to address any underlying causes and to correct internal control deficiencies. They will also report annually to the Audit Standing Committee information related to fraud allegations and investigations conducted during the year.

Any communication of fraud investigations must comply with the City's obligation to protect the privacy of its employees and to comply with all provisions of the Access to Information and Protection of Privacy Act, 2015. This includes legal and personnel matters. Council may decide to release the results of significant investigations that relate to the organization's public accountability.

Protections for Employees

Employees who are aware of fraud or who suspect fraud have a duty to report it. However, they may fear reprisals if they do so. The policy defines a reprisal as “any measure taken or threatened against a person as a result of making or being suspected of making an allegation or participating in or being suspected of participating in an investigation.”

Reprisals for disclosing fraud or suspected fraud will not be tolerated. The City will protect and support any employee who in good faith reports a suspected fraud.