1. General guidelines
The procedures that follow must be read in association with the Compliance Management Framework – Governing Policy and other related procedures.
2. Intent and objectives
The intent of this procedure is to:
- provide detailed elements relating to the operation and implementation of the University’s Compliance Management Framework;
- assign specific accountabilities and responsibilities for components of the University’s Compliance Management Framework; and
- enable the gathering of information to facilitate monitoring and reporting of compliance performance within the University.
3. Elements of the Compliance Management Framework
Successful achievement of the policy objectives will require recognition and incorporation of the following elements:
3.1.1 The Compliance Framework’s policy statement clearly articulates the University’s commitment to the maintenance and continuous improvement of a compliance management framework and processes, and to the development of a compliance culture throughout the University. To demonstrate its commitment the University will allocate appropriate resources to the development, implementation and continuous improvement of its compliance management framework.
3.1.2 Council, through the Audit and Risk Management Committee, is responsible for overseeing the University’s compliance with legislation, regulatory requirements, reporting obligations, and University policies.
3.1.3 Compliance is a shared responsibility between the University, management, staff, and University representatives.
3.1.4 Corporate Services will have overarching responsibility for:
a. the design and implementation of the Compliance Management Framework
b. coordinating the maintenance of, and promulgating the Register of Compliance Obligations and
c. monitoring and reporting on compliance.
3.1.5 All Cost Centre Managers will be accountable for the recognition and management of compliance risks in their area and for reporting on compliance.
3.1.6 All staff and agents of the University must be aware of compliance responsibilities that apply to their area of work or activities, and ensure that their actions on behalf of the University comply with relevant laws, industry codes and organisational standards.
3.2.1 The University will adopt a risk-based approach to the implementation of its compliance program. Statutory obligations representing the greatest degree of risk to the University will be given priority.
3.2.2 Compliance responsibilities will be identified and promulgated through the Register of Compliance Obligations.
3.2.3 Managers and staff will receive appropriate training in behaviours that create and support compliance.
3.2.4 Behaviours that create and support compliance will be encouraged. Behaviours that compromise compliance will be investigated.
3.3 Monitoring and measurement
3.3.1 Systems, procedures and controls will be implemented to support the monitoring of compliance obligations against the requirements of the Compliance Management Framework.
3.3.2 Corporate Services will be responsible for reviewing and maintaining the Register of Compliance Obligations, the Compliance Management Framework – Governing Policy and systems which support the compliance management framework within the University.
3.3.3 Compliance obligations and the assurance processes associated with these obligations will be assigned to University officers to ensure that obligations are actively monitored and that appropriate, ongoing assurance activities are undertaken.
3.3.4 Cost Centre Managers will be requested to confirm to the Chief Operating Officer at least twice yearly to provide assurance that these obligations are being monitored and managed. Minimum reporting requirements are:
a. the annual compliance reporting process undertaken mid-year to the Audit and Risk Management Committee; and
b. End of Year Declarations required of University Executive and Senior Staff Management as part of the preparation and completion of the University’s Annual Financial Statements.
3.3.5 Corporate Services will report at least annually to Council on the University’s framework program, via the Audit and Risk Management Committee.
3.4 Continuous improvement
3.4.1 The Compliance Management Framework - Governing Policy and Register of Compliance Obligations will be reviewed on an ongoing basis by Corporate Services to identify deficiencies and ensure continuous improvement to the framework.
4. Register of Compliance Obligations
4.1 The Chief Operating Officer is responsible for maintaining a Register of Compliance Obligations.
4.2 The Register of Compliance Obligations will be updated as an ongoing activity and will be promulgated on the University of the Sunshine Coast Portal.
4.3 Cost Centre Managers are responsible for the currency of Compliance Obligations recorded in this Register against their Cost Centre.
4.4 Cost Centre Managers should convey to the Chief Operating Officer advice of any new obligations or any changes to existing ones.
5. Accountabilities and responsibilities
6. Records management
All University records relating to compliance must be captured in the University's records management system.
The University of the Sunshine Coast acknowledges compliance policies from the following universities’ in the preparation of this policy and its associated procedures:
Central Queensland University
Queensland University of Technology
University of Newcastle
University of Southern Queensland