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Whistle-blower Program: the process

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The Whistle-blower Program (WBP) process provides assurance that each concern reported is given an equal and objective review. Appropriate investigation is made by professional staff experienced in conducting confidential investigations.

All activities of the WBP are confidential and shared only on a need-to-know basis or as necessary in order to conclude on the investigation and/or recommend corrective action. The WBP does not provide details on any investigation or disciplinary action taken by management.

Report Concerns

Report concerns to the Whistle-blower Program.

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The WBP communicates with whistle-blowers as the issue progresses through the various phases described below.

WBP reporting process flowchart

Report intake

Where possible, confirmation of receipt of reported concerns is provided within 2 working days. An initial assessment of the reported concern is made to identify exceptions and direct certain matters outside the WBP.


During this phase, each concern is assessed in detail to ensure that it meets WBP reporting criteria and contains sufficient information necessary to investigate. As necessary, a Triage Team recommends the best course of action, which may include further investigation. Some concerns can be concluded by the assessment process and not require additional investigation.

Following assessment, the WBP will advise of the disposition of the reported concern.

Referral or investigation

Each matter assessed has 3 options: referral, investigation, or no further action.

Referral: On occasion, a reported concern is determined to not require a whistle-blower investigation. If it is determined that management should be aware of an issue, that issue is directed to the relevant City department for action. On referral, the WBP considers the matter closed.

Investigation: Investigations are conducted by or under the direction of the WBP investigation team, which can resource investigators from Corporate Security, subject matter experts from Human Resources, or management. The commencement of an investigation is determined through a risk-based prioritization process which considers other active investigations in queue.

No Further Action: Some matters do not require further action beyond assessment. Where evidence during the assessment stage can be located demonstrating the actions were appropriate, a formal investigation is not required.


Results are documented and as necessary, substantiated allegations are shared with the appropriate City Department General Manager for appropriate action and to consider any corrective actions recommended.

Any reporting generated during an investigation is solely for the purpose of documenting investigative activity, results, and conclusions, in support of maintaining strong investigative practices. Report content is not intended to be distributed to, or shared with, any person, for any purpose not directly related to the purpose of the investigation and/or related corrective action.

Recommendations and closing

Following investigation, the WBP will advise whether the alleged waste and/or wrongdoing was substantiated or unsubstantiated. Due to the sensitive and personal nature of information collected, specific details of whistle-blower investigations are disclosed only on a need-to-know basis.

Any opportunities for improvement identified by the investigation are provided to management.

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