Fraud and Corruption Control - Governing Policy

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Fraud and Corruption Control - Governing Policy

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Approval authority
Council
Responsible officer
Vice-Chancellor and President
Designated officer
Chief Operating Officer
First approved
23 February 2016
Last amended
17 March 2016
Effective start date
17 March 2016
Review date
23 February 2021
Status
Active
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Student Academic Integrity - Governing Policy
Related legislation / standards
Public Interest Disclosure Act 2010
University of the Sunshine Coast Act 1998 (Qld)
Financial and Performance Management Standard 2009 (Qld)
Financial Accountability Act 2009 (Qld)
Crime and Corruption Act 2001 (Qld)
Australian Standard AS ISO 196000:2015 Compliance management systems

1. Purpose of policy

It is the purpose of this policy to give effect to the University’s commitment to prevent and control fraud and corruption. The University recognises that fraud and corruption management is an integral part of good governance and management practice and is consistent with the University’s Staff Code of Conduct – Governing Policy and all relevant legislation and standards.

2. Policy scope and application

2.1 This policy applies to all staff, students, contractors and members of University decision-making or advisory bodies, including the University Council and its Committees.

2.2 The policy is based on the guidelines and principles of the Financial Accountability Act 2009, Crime and Corruption Act 2001 (CC Act) and the Australian Standard: AS8001-2008 Fraud and Corruption Control (the Australian Standard).

3. Definitions

Please refer to the University’s Glossary of Terms for policies and procedures. Terms and definitions identified below are specific to this policy and are critical to the effectiveness of it.

Corruption is dishonest activity in which a director, executive, manager, employee or contractor of an entity acts contrary to the interests of the entity and abuses his/her position of trust in order to achieve some personal gain or advantage for him or herself or for another person or entity. The concept of ‘corruption’ within this standard can also involve corrupt conduct by the entity, or a person purporting to act on behalf of and in the interests of the entity, in order to secure some form of improper advantage for the entity either directly or indirectly. (According to the definition of corruption from the Australian Standard.)

Fraud is dishonest activity causing actual or potential financial loss to any person or entity and also includes the deliberate falsification, concealment, destruction or use of falsified documentation used or intended for use for a normal business purpose or the improper use of information or position for personal financial benefit. (Based on the definition of fraud from the Australian Standard.)

Corrupt Conduct as defined in section 15 of the CC Act.

4. Regulatory background

4.1 The University is established under the University of the Sunshine Coast Act 1998 (Queensland legislation); it is a statutory authority, and as such falls within the jurisdiction of the Crime and Corruption Commission (CCC) as a unit of public administration. Under the Crime and Corruption Act 2001 (CC Act), any acts which could amount to Corrupt Conduct must be notified to the CCC by the Vice-Chancellor and President, as the University’s chief executive officer (or public official), in accordance with section 38 of the CC Act.

4.2 The Financial Accountability Act 2009 requires the University to establish and maintain appropriate systems of internal control and risk management.

4.3 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.

4.4 Consistent with the approach adopted by the CCC in its publication Fraud and Corruption Control: Guidelines for Best Practice (2005) fraud and corruption are not treated separately in this policy.

5. Policy statement

5.1 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 in all University activities consistent with its Codes of Conduct and the law.

5.2 The objectives of this policy are to ensure the University:

  • develops and maintains an organisational culture of honesty and integrity,
  • puts in place processes that ensure effective prevention, detection and management of fraud and corruption, based on the Australian Standard AS8001-2008: Fraud and Corruption Control and the Crime and Corruption Commission’s “Fraud and corruption control: guidelines for best practice”, and
  • encourages, supports and protects persons who report suspected fraud and corruption.

6. Fraud and corruption control framework

6.1 Elements

This policy is based on the CCC's 10 element best practice control model, which is consistent with national and international best practice. The elements are:

1. University wide integrated policy

2. risk assessment

3. internal controls

4. internal reporting

5. external reporting

6. public interest disclosures

7. investigations

8. code of conduct

9. staff education and awareness

10. client and community awareness

6.2 Themes

These elements are addressed in the related procedures and enshrine the key themes from the Australian Standard which are:

  • planning and resourcing,
  • prevention,
  • detection, and
  • response.
6.3 Framework

The University’s Fraud and Corruption Control Framework (refer Diagram 1) comprises the above elements and themes and it is anticipated that the implementation of this policy will serve to:

  • protect the University's assets, interests and reputation;
  • ensure a transparent and 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.

Diagram 1 – Fraud and Corruption Control Framework

7. Reporting and protected disclosure

7.1 Where a staff member is aware of, or suspects, fraudulent or corrupt conduct they must report these suspicions immediately. Staff should do so in accordance with the University’s Public Interest Disclosure – Governing Policy. Legislative protection is accorded to staff members who make disclosures under the Public Interest Disclosure – Governing Policy.

7.2 Under the Crime and Corruption Act 2001 (Qld) (CC Act) , any acts which could amount to corrupt conduct must be notified to the CCC by the Vice-Chancellor and President, as the University’s chief executive officer (or public official), in accordance with section 38 of the CC Act.

7.3 Confidentiality must be maintained throughout any investigative process.

8. Authorities and Responsibilities

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Activity (refer to procedures for further detail) University Officer
Responsible for:
  • approving Policy; and
  • ensuring adequate reporting on compliance from Audit and Risk Management Committee.
University Council
Responsible for:
  • all fraud and corruption matters and decision-making;
  • referring to, or notifying, relevant external agencies of allegations of suspected fraud or corrupt conduct in accordance with legislative requirements, as well as assessing and dealing with allegations within the University;
  • notifying Audit and Risk Management Committee and internal audit of allegations of suspected fraud or corrupt conduct;
  • communicating the expectation that all employees are required to conduct their duties to high professional and ethical standards and always act in the public interest; and
  • ensuring that appropriate and effective internal controls systems are in place that will assist in preventing and detecting fraud and corruption.
Is an Appointing Officer under this Policy and is responsible for appointing an Investigations Officer, who may be internal audit or an external party to the University, when investigation is required.
Vice-Chancellor and President
Responsible for:
  • providing high level advice to the Vice-Chancellor and President and senior management on procedural matters to strengthen risk management and proactively provide leadership and support of this policy and its objectives; and
  • maintaining policies and procedures and records in relation to fraud and corruption control.
Is an Appointing Officer under this Policy and will be responsible for appointing an Investigations Officer, who may be internal audit or an external party to the University, when investigation is required.
Chief Operating Officer
Responsible for ensuring that appropriate mechanisms are in place within their areas of control to:
  • establish controls and procedures for prevention and detection of any fraudulent or corrupt conduct;
  • identify risk exposures to fraudulent and corrupt conduct and ensuring that regular assessment of the risks are undertaken;
  • promote awareness amongst staff of this policy and of the ethical principles subscribed to by the University;
  • advise the Vice-Chancellor and President of any reported allegations of fraud or corrupt conduct, enabling the Vice-Chancellor and President to fulfil the University’s obligations under the Crime and Corruption Act 2001;
  • assist staff to analyse and work through issues in fraud and corruption prevention and detection;
  • ensure prompt and positive responses to allegations or indications of fraudulent and corrupt acts; and
  • complete and sign End of Year Internal Controls declarations required as part of the preparation and completion of the University’s Annual Financial Statements.
University Executive and Management
Responsible for undertaking their duties in accordance with the University’s Staff Code of Conduct. Responsible to:
  • immediately report any suspected fraudulent or corrupt activity of which they become aware to their supervisor, Cost Centre Manager or, if appropriate, another member of executive staff or internal audit;
  • assist with any enquiries or investigations pertaining to fraudulent and corrupt activity where requested by an appropriately authorised officer.
All University staff
Responsible to ensure all matters relating to (alleged) fraud or corrupt conduct are dealt with appropriately. Responsible for approving the Fraud and Corruption Control Plan. Audit and Risk Management Committee
Responsible for:
  • monitoring and evaluating the effectiveness of internal controls and risk management processes in preventing and detecting fraudulent or corrupt conduct;
  • advising the Audit and Risk Management Committee and the Vice-Chancellor and President of any allegations of fraudulent or corrupt conduct reported to it or identified through routine or random audits; and
  • conducting investigations into allegations of fraudulent or corrupt conduct referred to it by the Appointing Officer.
Senior Internal Auditor

END

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