Wrongdoing: Refers to any serious act (or failure to act) which:

• causes resources or property of Toronto Seniors Housing Corporation (TSHC) to be lost or misused (fraud or waste)
• goes against TSHC policies, procedures, or directives
• risks the health or safety of tenants, employees, or visitors to TSHC sites
• breaks any city, provincial or federals laws
• involves knowingly telling or advising someone else to do any of these things
• is done to hide something that is not allowed under TSHC’s Whistleblower Protection Policy (the rules about reporting wrongdoing)

Fraud is when someone does something with the idea to trick or deceive others.

At TSHC, fraud includes any misuse or attempted misuse of TSHC materials, equipment or buildings for someone’s personal gain or for reasons not related to their job. Personal gain also means doing something for a family member or a friend.

It is also considered fraud if someone uses their position at TSHC for personal gain or gains that may benefit a family member or friend.

Fraud affects everyone at TSHC. When money is lost because of dishonest actions, it limits TSHC’s ability to spend money on needed repairs and offering programs for the community. This can lead to negative consequences, like people waiting longer to move into a TSHC home.

TSHC wants to be honest, ethical and responsible. To maintain trust, TSHC wants people to be able to report any serious wrongdoing they see within the organization.

The Whistleblower Protection Policy is there to explain how to report wrongdoing and to protect people who report it honestly from getting punished (reprisal) for speaking up.

The Policy protects TSHC employees and Board members who report wrongdoing honestly. It also encourages tenants and the public to report wrongdoing and offers them reasonable protection from being threatened (reprisal) for doing so.

Please report if you think a tenant is doing any of the following:

• not reporting changes in who lives with them:
  • having people who live there who are not on the lease
  • providing the wrong number of occupants to maintain a larger unit
• rent out (sublet) all or part of a subsidized unit to someone else
• do not tell TSHC about all the money they make or what they own (assets)
• provide wrong or altered income details
• fail to report that a person in their household was a student and is not anymore
• not reporting that they have been away from their unit beyond what is allowed (Absences from RGI unit guidelines)
• not reporting that they own another house or property
• use their position unfairly – this includes breaking the rules of the TSHC Community Activities Fund (CAF) Policy and Tenant Volunteer Code of Conduct. For example:
  • charging other tenants extra money to join an event paid for by CAF
  • using CAF money to buy things for themselves
  • not telling TSHC if they are related to someone being paid with CAF money for a service

In an emergency, always call 9-1-1.

Please do not use the Fraud and Ethics Hotline for:

• Maintenance problems: Leaks, pests, broken appliances (for example: washers, dryers).
  • Report these to the Tenant Support Centre at 416-945-0800 or support@torontoseniorshousing.ca.

• Safety and security issues: Security problems, loud noise, people hanging around or trespassing, drug activity, threats, theft of TSHC property, damage to TSHC property, parking rule violations.
• Report these to the Community Safety Unitat 416-921-2323.
• City by-law issues: Call the City of Toronto at 311.

For more information, please review the Fraud Prevention Policy and Whistleblower Protection Policy.

Please report if you suspect an employee, Board member, contractor, or vendor is doing any of the following:

• misusing TSHC property (including equipment, materials, records and confidential information)
• using their power unfairly for personal gain or breaking TSHC’s Employee Conflict of Interest Policy and Board of Directors Conflict of Interest Policy
• threatening someone to get what they want (extortion)
• stealing or misusing TSHC property (including funds, supplies, equipment, software)
• changing or making fake cheques, records, or other important papers
• taking company money unfairly
• making an unfair profit using company information
• acts of bribery – offering, giving, asking for, or accepting secret payments or valuable things from vendors, contractors, tenants, or housing applicants
• destroying or damaging TSHC property on purpose
• sharing secret company information with outsiders
• any other improper dealings with tenants, vendors, or agencies
• anything illegal, unethical, unsafe or fraudulent

If you are not sure whether or not to report something, it is better to report it anyway. If your concern is not about wrongdoing or fraud, you may be directed to the Tenant Support Centre at 416-945-0800 or the Community Safety Unit at 416-921-2323.

In an emergency, always call 9-1-1.

Non-emergency criminal activity should be reported to the Toronto Police Crime Stoppers at 416-222-TIPS (8477) or the Community Safety Unit at 416-921-2323.

If you have a human rights concern, you should refer to the Tenant Human Rights Policy and related information.

There are three ways to report cases of suspected wrongdoing or fraud.

• Phone: 1-866-781-7956 (24 hours/7 days)
• Online: Submit using the secure online form and choose Toronto Community Housing Corporation (TCHC) and Toronto Seniors Housing Corporation (TSHC) as organization name.
• Mail: ClearView Connects, PO Box 11017, Toronto, ON M1E 1N0
• Your information always remains private. Reporting is not recorded or traced. All reports are sent securely to TSHC for further action.

Please provide the following information to support your report:

• What is your complaint? Review the types of wrongdoing and fraud complaints above. Provide as much information as you can.
• Where did the suspected incident occur? Please list the TSHC location where the suspected incident happened. This will help make sure it is being reported and investigated using the correct method.
• Who are the people involved? For example, names of tenants, staff, contractors, or other people.
• How long do you think the suspected wrongdoing or fraud has been taking place?
• Who else may be aware of the incident? For example, police, media, staff or other individuals.

Online: When you submit a report online, you will get a unique, seven-digit report number and an eight-digit password. These are only for your report and you will need them again so please write them down. You can change the password later, if you want.

You can also provide an email address to get updates on your report. This is optional. TSHC will not see your email address. It is only for the reporting system to send you notification emails. The system will delete your email when you stop the updates, do not log in for 90 days, or the report is closed.

Phone: If you phone the Fraud and Ethics Hotline, the person on the phone will give you a seven-digit report number and an eight-digit password. They will also set up a secret question with you, where your answer is a six-digit number (year and month, like 195008 for August 1950).

If you call back to check your report, you will not need to give the password over the phone. You can just answer your secret question. Interpreters are available if you need help in another language.

Mail and voicemail: If you choose to submit your report by voicemail or submit a handwritten or typed letter, there is no option for further follow up as you are not assigned a seven-digit report number.

TSHC will look into any suspected fraud, corruption (dishonest actions by people in charge), or other wrongdoing. This includes tenants misusing Community Activity Funds or Rent-Geared-to-Income (RGI) fraud.

Every report will be investigated, no matter who is involved or their role at TSHC.

All investigations will be kept private and done fairly without bias. TSHC might involve managers from other departments, the police, or other experts to help.

The following is what generally happens after you report wrongdoing or fraud online, by phone, or in writing:

• The Clearview Connects system (now owned by Mitratech) records your report and sends it to the Toronto Community Housing Corporation (TCHC) Investigations Unit.
• If your report involves TSHC staff, Board members, contractors, vendors, the TSHC Investigations Unit sends it to TSHC’s Director, People and Culture. If it is about a Board member, the Director sends it to the Board Chair. If it is about the Director, People and Culture it goes to TSHC’s Chief Executive Officer (CEO).
  • The Director, People and Culture (or CEO) looks at the report to see how serious it is. They might try to find more information to check if the report is true. If you did not report anonymously, they will let you know they got your report within 10 business days.
  • Based on what they find, the Director, People and Culture (or CEO) will either investigate the issue themselves, send it to someone else to investigate (like another TSHC expert or an outside investigator), or close the case. They might close it if there is not enough information, if it is not actually wrongdoing or fraud, or if it is not a TSHC issue.

• If your report involves TSHC tenants the TSHC Investigations Unit sends it to TSHC’s Director, Operations. They make sure the reports of RGI fraud follows the City of Toronto’s rules. The Director, Operations forwards reports about misusing Community Activities Funds to the Manager, Community Programs and Partnerships for investigation.
  • Reports of fraud that are not managed under the TSHC’s Fraud Prevention Policy will be sent to the right investigator and looked into following TSHC’s Whistleblower Protection Policy. Reports about Toronto Community Housing Corporation (TCHC) staff will be sent to TCHC’s own Investigations Unit.

Yes, you can report wrongdoing or fraud without saying who you are:

Online: The system used makes sure your report is secret and safe. You can choose not to give your name. To stay anonymous, do not include personal information in the report that could identify you. Your report is encrypted, and your computer’s internet address is not tracked.

Phone (in person): If you talk to someone on the phone, the call is not recorded, and they do not see your phone number. They type your report exactly as you say it.

Phone (voicemail): If you leave a voicemail, they type it into the system exactly as you said it and then your voicemail is deleted. They do not see your phone number.

Mail: If you mail a report, they will type it into the system or scan it. The original paper version is destroyed. Only the reporting system staff can access the mailbox.

In all cases, your report stays on secure servers in Canada.

If you are reporting concerns about a Special Constable within TCHC’s Community Safety Unit, you cannot stay anonymous/secret. This is because of a law called the Community Safety and Policing Act, 2019 which says reports about Special Constables cannot remain anonymous.

Like other peace officers, these concerns must be written down. The review of the complaint will follow rules set out in the Comprehensive Ontario Police Services Act, 2019. The Special Constable the report is about will be told about it.

TSHC’s rules say staff cannot accept gifts, benefits, or favours in exchange for special treatment, or it looks like it could be. This includes cash, loans, gifts that seem look like a bribe, gifts from companies or people who might want to (or do) work with TSHC.

However, staff can accept small thank-you gifts around the holidays, like cards, cookies, candy, or chocolates worth less than five dollars. Things like calendars, note pads, and pens with company logos are also fine.

TSHC’s rules say that Board members cannot accept fees, advances, gifts, money, discounts, donations, benefits, meals, tickets, or loans from tenants or anyone doing business with TSHC if it could influence their decisions.

The only exceptions are very small gifts that would not influence or look like they would influence how a Board member does their job.

Board members should not accept things like meals, offers of donations to their favourite charities, or invitations to events paid for by others.