Fraud and Corruption Control Policy
Responsible officer: Vice-Chancellor
Designated officer: Chief Financial Officer
Council approval: Resolution C06/64, 13 June 2006
Related policies:
Related legislation:
- Freedom of Information Act 1992
- Whistleblowers Protection Act 1994
Overview
Implementing effective fraud and corruption controls is part of good governance and management practice. Such controls seek to minimise the risk, not only of financial loss, but also of damage to an organisation's reputation and that of its staff.
Policy
The University of the Sunshine Coast has a zero tolerance stance on fraud and corruption and is committed to minimising the risks of such behaviour and ensuring continuing organisational integrity and transparency of operation.
1. Definitions
According to the Crime and Misconduct Commission (CMC):
Fraud is normally characterised by some form of deliberate deception to facilitate or conceal the misappropriation of assets, whereas corruption involves a breach of trust in the performance of official duties.
Fraudulent and corrupt conduct may constitute 'official misconduct' under the Crime and Misconduct Act 2001 and/or an offence under the Criminal Code 1899.
Consistent with the approach adopted by the CMC in its publication Fraud and Corruption Control: Guidelines for Best Practice (CMC 2005) fraud and corruption are not treated separately in this policy.
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2. Objective
The objective of this policy is to implement the first step in the CMC's 10 element best practice control model, which is consistent with national and international best practice. The elements are:
- University wide integrated policy
- risk assessment
- internal controls
- internal reporting
- external reporting
- public interest disclosures
- investigations
- code of conduct
- staff education and awareness
- client and community awareness
It is anticipated that the introduction of this policy will serve to:
- protect the University's assets, interests and reputation
- ensure a coordinated approach in dealing with suspected fraudulent and corrupt behaviour, and
- where appropriate, safeguard the reputation of individuals subject to the operation of this policy
3. Application
This policy applies to all staff of the University.
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4. Roles and responsibilities
Vice-Chancellor
The Vice-Chancellor has ultimate responsibility for all matters relating to this Policy, including the prevention and detection of fraud, and ensuring that appropriate and effective internal controls systems are in place.
The Vice-Chancellor is also responsible for referring to or notifying relevant external agencies of allegations of fraudulent and corrupt behaviour that have been dealt with by the University
Chief Financial Officer
The Chief Financial Officer will provide high level advice to the Vice-Chancellor and senior management on procedural matters to strengthen risk management and will proactively provide leadership in support of this policy and its objectives.
The Chief Financial Officer has responsibility for coordination of the implementation of this Policy.
Audit and Risk Management Committee
The Audit and Risk Management Committee is responsible for review of processes to ensure that all matters relating to (alleged) fraud or unethical conduct are dealt with appropriately.
Executive and management staff
Executive and management staff have a special responsibility to ensure that appropriate mechanisms are in place within their areas of control to:
- assess the risk of corruption and fraud
- promote awareness amongst staff of this policy and of the ethical principles subscribed to by the University
- assist staff to analyse and work through issues in fraud and corruption prevention and detection, and
- ensure prompt and positive responses to allegations or indications of fraudulent and corrupt acts
Staff
If staff become aware of fraudulent and corrupt activity, it is their responsibility to immediately report such activity to their supervisor, Cost Centre Manager or, if appropriate, another member of executive staff or Internal Audit. Staff members are expected to assist with any enquiries or investigations pertaining to fraudulent and corrupt activity.
All Queensland Government agencies are required to appoint a Liaison Officer to the Crime and Misconduct Commission (CMC). CMC Liaison Officers are not employees of the CMC. They are responsible people within an agency who are nominated by the agency to represent the agency in dealings with the CMC. CMC Liaison Officers have a responsibility to tell the CMC immediately of any suspicion of misconduct or official misconduct, in accordance with section 15 of the Crime and Misconduct Act.
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5. Complainant protection
No staff members will be criticised or otherwise disadvantaged for making a suspicion known through the proper channels, unless the allegation is found to be frivolous and/or vexatious.
6. Internal control structures
The University has established internal financial and management controls, which require staff to follow standard practices when conducting University business, to act in accordance with best practice, and to adhere to agreed internal control systems.
Applicable internal controls include:
- suitable recruitment procedures (eg contacting referees, and verifying transcripts, publications and other certification documentation)
- segregation of duties
- security of records and information systems
- consideration of risk and risk management strategies
- supervision and internal checks
- approvals within delegated authority
- reconciliations
- budget control
- regular review of management reports
- clear reporting lines, and
- internal audit
The University's internal audit program is to include both systematic and random audits to test compliance, and effectiveness of internal controls. The findings of these audits are reported to the Audit and Risk Management Committee, and thence to Council, so that any identified adverse trends or deficiencies are acted upon.
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7. Confidentiality
Confidentiality will be maintained throughout any investigative process.
8. Communicating with the media and the public
The University recognises not only the legitimate right of the media to follow up matters, which may be in the public interest, but also the importance of keeping the community informed of significant matters affecting the University and its operation. The University will take a proactive approach to communicating with the media and the community on all matters of suspected fraud and corruption.
9. Staff development and training
Staff development and training is a key component in combating fraudulent and corrupt behaviour. To that end:
- induction procedures will include making new staff aware of this policy, and
- the Chief Financial Officer and CMC Liaison Officer will work with Human Resources to improve awareness of issues in fraud and corruption, risk management and internal controls, and to develop prevention training for management and staff.
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