Policy

Fraud and Corrupt Conduct - Policy

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1.0  Purpose and Scope

1.1  Purpose

The University of Queensland (UQ) has zero tolerance for, and denounces all forms of, fraud and corruption. This includes 'Corrupt Conduct' as defined by the Crime and Corruption Act 2001 (CC Act), which may include fraud. The definition of corrupt conduct is provided in the appendix of this policy.

The CC Act places statutory obligations on UQ to report all matters that involve or may involve corrupt conduct to the Crime and Corruption Commission (CCC). UQ is committed to managing its fraud and corruption risks and to advancing the purpose of the CC Act, which is to combat and reduce the incidence of major crime and corruption in the public sector.

In addition to this policy, UQ’s framework for the overall management for fraud and corruption risks, including the reporting, assessing, preventing, detecting and investigating instances or suspicions of fraud or corrupt conduct, comprises:

  1. the Complaints of Corrupt Conduct against the Vice-Chancellor and President Policy; and
  2. the Fraud and Corrupt Conduct Procedure.

UQ will report and record complaints of corrupt conduct (which may include fraud) consistent with its obligations under s40 and s44 of the CC Act and with its obligations under the Public Records Act 2002.

UQ acknowledges the importance of transparency when dealing with matters of reasonably suspected fraud or corrupt conduct and of ensuring it upholds the highest standards of integrity and accountability.

1.2  Scope

This policy applies to all UQ staff, affiliates, volunteers and members of UQ Senate. The definition of UQ staff, affiliates and volunteers is provided in the appendix.  

As required under the CC Act, UQ’s Complaints of Corrupt Conduct against the Vice-Chancellor and President Policy addresses how complaints that involve or may involve reasonably suspected corrupt conduct by the Vice-Chancellor and President are to be dealt with. 

2.0  Principles and Key Requirements

  1. To give effect to its position of zero tolerance for fraud and corrupt conduct and to meet its legislative obligations, UQ will:

    1. Implement effective UQ-wide anti-fraud and anti-corrupt conduct procedures.

    2. Take all reasonable steps to proactively establish a culture and an operating environment that denounces all fraud and corrupt conduct.

    3. Effectively manage the risks of fraud and corrupt conduct.

    4. Encourage and facilitate, through planning and provision of resources, the identification and honest disclosure of reasonably suspected fraud or corrupt conduct.

    5. Unless directed otherwise by the CCC, promptly refer complaints to the CCC for assessment where UQ reasonably suspects corrupt conduct.

    6. Investigate and report on all complaints and allegations of fraud or corrupt conduct.

    7. Discipline those who have engaged in corrupt conduct, notwithstanding their position and power.

    8. Promptly address any deficiencies in controls or culture.

    9. Develop and implement training that raises awareness regarding culture, accountability and internal controls.

    10. Deal with frivolous or vexatious complaints including the possible commencement of disciplinary actions.

    11. Treat all allegations of reasonably suspected fraud or corrupt conduct confidentially.

  2. The Fraud and Corrupt Conduct Procedure details the minimum mandatory requirements of all UQ staff, affiliates and volunteers in implementing the above key requirements within UQ.

  3. Failing to comply with this policy may be a breach of UQ’s Code of Conduct and may also be considered corrupt conduct under the CC Act. Non-compliance may lead to disciplinary action, including dismissal. 

3.0  Roles, Responsibilities and Accountabilities

3.1  Vice-Chancellor and President

The Vice-Chancellor and President is the public official of UQ and is responsible for:

  • Ensuring UQ has appropriate policy, training and awareness initiatives and other control systems in place to prevent, detect and manage corrupt conduct (including fraud) incidents.

  • Setting the tone of the organisation, including leading and promoting an ethical culture.

  • Encouraging reporting of reasonably suspected corrupt conduct.

  • Ensuring appropriate action is taken in respect to corrupt conduct and fraud.

3.2  Heads of Organisational Units

Heads of Organisational Units are responsible for promoting this policy and related procedure to all staff, affiliates and volunteers within their respective areas of control and ensuring there are effective control systems in place to manage fraud and corrupt conduct.

3.3  Integrity and Investigations Unit

The Vice-Chancellor and President has authorised the Director, Integrity and Investigations Unit (IIU) to refer matters of reasonably suspected corrupt conduct to the CCC. The IIU will also:

  • assess and investigate fraud and corrupt conduct matters;

  • implement strategies across UQ to mitigate against risks of fraud and corrupt conduct; and

  • inform Internal Audit of any systemic breakdown of internal controls identified at the conclusion of an investigation for consideration in the Internal Audit planning process.  

3.4  Internal Audit

Internal Audit will report any cases identified as possible fraud and corrupt conduct to the IIU for further assessment. 

3.5  UQ Staff, Affiliates and Volunteers

All UQ staff, affiliates and volunteers have, pursuant to the Code of Conduct, a responsibility to report concerns of reasonably suspected fraud in or involving the workplace or corrupt conduct to any of the following:

  • their supervisor or senior management in their work area

  • Human Resources

  • Integrity and Investigations Unit (IIU)

  • Chief Operating Officer.

Reports of reasonably suspected corrupt conduct can also be referred directly to the CCC.

All complaints involving reasonably suspected fraud and/or corrupt conduct must be referred to the Director, IIU for proper assessment and where necessary, referral to the CCC.

Staff, affiliates and volunteers also have an obligation to participate in training that raises awareness regarding culture, accountability and internal controls as it applies to fraud and corrupt conduct.

4.0  Monitoring, Review and Assurance

The Director, IIU is responsible for the promotion of this policy and the related procedure and for ensuring that they are regularly reviewed for currency and effectiveness.

The Director, IIU will continually monitor and review actions for the purpose of:

  • assessing compliance with the policy and to demonstrate/confirm its effectiveness;

  • identifying, assessing and promptly addressing any deficiencies;

  • ensuring ongoing relevance of the policy;

  • assessing effectiveness of controls; and

  • reporting through the Chief Operating Officer on weaknesses in controls as appropriate.

5.0  Recording and Reporting

The IIU will record all reported or detected incidents of fraud or corrupt conduct within its
Complaints Management Database. 

The IIU will prepare and submit reports on current matters and trends involving fraud or corrupt conduct as required and where appropriate for statistical analysis and corrupt conduct prevention, and to the following parties as required or requested:

  • Complaints Management Committee

  • Vice-Chancellor’s Risk and Compliance Committee

  • Senate Risk and Audit Committee

  • the CCC

  • external auditors.

6.0  Appendix

6.1  Definitions

Affiliates – academic title-holders, visiting academics, emeritus professors, adjunct and honorary title-holders, industry fellows and conjoint appointments.

Complaint – an expression of dissatisfaction with a product or service offered or provided by UQ or the conduct of UQ staff, affiliates, volunteers or students (in so far as their role at UQ), whether voiced by a member of the community, staff, affiliate, volunteer or a student.  In relation to corrupt conduct, a complaint includes information or a matter of reasonably suspected corrupt conduct.

Corrupt Conduct – under s15 of the CC Act there are two different types of corrupt conduct known as ‘Type A’ and ‘Type B’:   

  • Type A involves conduct by any person that affects, or could affect, how officers from a
    Unit of Public Administration (i.e. the University) perform their functions or exercise their powers.

Some common examples of Type A corrupt conduct include fraud (e.g. misuse of a corporate credit card), unauthorised release of information or nepotism in recruitment.

  • Type B involves conduct by any person that impairs, or could impair, public confidence in public administration.

Type B corrupt conduct might include collusive tendering or dishonestly obtaining public funds or state assets. 

Each type of corrupt conduct has to satisfy three essential elements including that the conduct must be either a criminal offence or serious enough to warrant dismissal.  Further details about this essential criteria can be found at s15 of the CC Act and in the CCC’s guide 'Corruption in focus'.

Corruption – a broader term than corrupt conduct. Defined by Australian Standard 8001-2008 Fraud and Corruption Control as:

‘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’.

Fraud – defined by Australian Standard 8001-2008 Fraud and Corruption Control as:

‘Dishonest activity causing actual or potential financial loss to any person or entity including theft of moneys or other property by employees or persons external to the entity and where deception is used at the time, immediately before or immediately following the activity. This 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’. This definition of fraud can also encompass corrupt conduct.

Reasonably Suspects – under the CC Act 'reasonably suspects' means 'suspects on grounds that are reasonable in the circumstances'.  The 'Corruption in focus' guide adds that for a suspicion to be ‘reasonable’, there needs to be more than bare or idle speculation and that, in essence, there must be some evidence sufficient for a reasonable person to suspect corrupt conduct.

Staff – continuing, fixed-term, research (contingent funded) and casual staff members.

Volunteers – members of the community who donate their services in a voluntary capacity to UQ without expectation of remuneration. Volunteers include those undertaking work on fundraising and community-oriented projects, tertiary students wishing to gain exposure to particular UQ functions, among others.

Custodians
Director, Integrity and Investigations Mr David Lavell

Procedures

Fraud and Corrupt Conduct - Procedures

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1.0    Purpose and Scope

The potential damage to UQ’s credibility and loss of public confidence may far exceed any likely financial or material loss resulting from fraud and corrupt conduct. These factors underpin UQ’s zero tolerance approach to fraud and corrupt conduct, with the desired outcome being the prevention of all fraud and corrupt conduct related incidents involving UQ.

UQ’s strategy to prevent fraud and corrupt conduct will at all times support the protection of property, information, revenue, expenditure, and the rights of organisations and individuals. However, managing the risks associated with UQ’s financial and physical resources is only part of UQ’s strategy to prevent fraud and corrupt conduct.

This procedure supports The University of Queensland’s (UQ) Fraud and Corrupt Conduct Policy and identifies the minimum mandatory requirements for all UQ staff, affiliates, volunteers and members of Senate in the prevention of fraud and corrupt conduct. The definition of ‘corrupt conduct’, staff, affiliates and volunteers is provided in the appendix of this procedure.

This procedure does not specify how complaints or information that involves or may involve reasonably suspected Corrupt Conduct by the Vice-Chancellor and President (the public official of the University) are to be dealt with. Refer to the Complaints of Corrupt Conduct against the Vice-Chancellor and President Policy.

2.0    Process and Key Controls

UQ is committed to an integrated approach to prevent and control fraud and corrupt conduct at UQ or involving UQ. This approach is based on the ‘three lines’ assurance model and the key themes of the Australian Standard AS8001:2008 Fraud and Corruption Control (Australian Standard) including its guidance on planning and resourcing. The key themes are demonstrated by UQ’s efforts to Prevent, Detect and Respond to fraud and corrupt conduct risks.

  1. The key controls designed to prevent fraud and corrupt conduct at UQ include the development of a sound ethical culture through communication and awareness.

    1. UQ’s Code of Conduct states that all staff must not engage in corrupt or fraudulent conduct or maladministration, and should report genuinely suspected or known instances of fraud, corrupt conduct.

    2. All staff must complete Code of Conduct and Fraud and Corruption training and also attend induction programs as soon as practicable after commencing employment at UQ.

  2. The key controls designed to detect fraud and corrupt conduct include a responsibility on staff to report their concerns as soon as practical to their supervisor or senior manager in their work area or directly to UQ’s Integrity and Investigations Unit (IIU).  This is supported at UQ by:

    1. complaints management processes to facilitate the reporting of fraud and corrupt conduct concerns;

    2. processes and systems for post-transactional review and data mining; and

    3. internal and external audit activities.   

  3. The key controls designed to respond to identified instances of fraud and corrupt conduct include:

    1. the conduct of inquiries and investigations by suitably qualified and trained staff or external contractors;

    2. clear policies and procedures for dealing with incidences of fraud and corrupt conduct, including processes for referring matters to the Crime and Corruption Commission (CCC); and

    3. effective disciplinary proceedings.

3.0    Key Requirements

3.1    Organisational Commitment

To give effect to its position of zero tolerance of fraud and corrupt conduct and to meet its legislative obligations UQ will:

  1. Take all reasonable steps to proactively establish a culture and an operating environment that overtly and emphatically denounces fraud and corrupt conduct at UQ, including the strong endorsement of this policy and procedures.

  2. Effectively manage the risks of fraud and corrupt conduct at UQ by:

    1. Assessing the risks of fraud and corrupt conduct in all its operations, business activities and projects.

    2. Designing and implementing appropriate controls to manage the risks, paying particular attention to minimising the opportunities for engaging in fraud and corrupt conduct.

    3. Monitoring and reviewing the effectiveness of the controls and addressing any deficiencies. 

    4. Providing assurance on the effective management of the risks of fraud and corrupt conduct.

  3. Encourage and facilitate, through planning and provision of resources, the identification and honest disclosure and reporting of activities and behavior that are fraud and corrupt conduct or appear to be so.

Unless directed otherwise by the CCC, the IIU will refer all corrupt conduct allegations to the CCC for assessment. Investigations will be conducted in accordance with the UQ’s Complaints Management Policy and Procedures as well as the CCC’s guide ‘Corruption in focus’.

Substantiated allegations will be referred to the appropriate decision-maker for consideration.

3.1.1   Public Interest Disclosures

UQ will manage public interest disclosures (PID) in accordance with its Public Interest Disclosure Policy and Procedures.

3.1.2    Corrective Measures – Systemic Issues

Following an investigation into suspected fraud and corrupt conduct, evidence must be provided to the IIU on request from management to demonstrate how systemic issues were dealt with, including what corrective measures were taken to eliminate or minimise the risks that were identified. 

3.2    Prevention

3.2.1    Internal Controls

UQ ensures its internal controls are sufficient to manage corporate risk through its commitment to the ‘Three lines of defence’ assurance model.

3.2.2    Staff Training and Awareness

Staff training can go beyond Code of Conduct and Fraud and Corruption Awareness Training and may also include additional training on:

  • culture awareness

  • accountability

  • internal controls.

UQ’s Staff Development portal provides access to staff training schedules.

3.2.3    Risk Assessment

UQ will conduct fraud and corrupt conduct risk assessments in accordance with its Enterprise Risk Management Framework (ERMF) to assess how the level and type of risks to UQ should be addressed.

3.3    Detection

3.3.1    Reporting reasonably suspected cases of fraud and corrupt conduct

UQ will ensure the proper reporting of all reasonably suspected cases of fraud and corrupt conduct and will provide protection for those that report fraud and corrupt conduct from harm for doing so. Where appropriate, protection will be provided to those that disclose these types of matters under the Public Interest Disclosure Act 2010 and the relevant UQ policy.

3.3.2    Data mining and post-transactional review

UQ conducts real time computer system analysis using systems such as Continuous Control Monitoring (CCM) to identify fraudulent transactions and potential integrity risks such as a vendor having the exact same address or bank details as a staff member.

3.3.3    Internal audit

The internal auditing of UQ transactions will, depending on the circumstances, identify activities, trends and risks which of themselves could be prima facie evidence of fraud and/or corrupt conduct, or will after further investigation reveal evidence of potential inappropriate behaviour.

3.3.4    External audit

Where financial statements are audited, UQ is to be aware of the role and responsibilities of the external auditor in detecting fraud. UQ will discuss the audit procedures with the external auditor to establish what efforts will be carried out to detect material misstatements in financial records due to potential fraud or error.

3.4    Response

3.4.1    Investigation

UQ will thoroughly and objectively investigate and report on complaints and allegations of fraud and corrupt conduct. UQ will deal with all such matters in accordance with any relevant CCC recommendation or direction and relevant UQ policies and procedures.

Where possible, confidentiality will be maintained at all times during an investigation. No information will be disclosed to other persons unless required or permitted by law.

3.4.2    External investigators

In limited situations UQ may engage an external investigator. 

Where the matter may involve a PID and/or reasonably suspected corrupt conduct it is vital that the external investigator is made aware of UQ’s obligations under the Public Interest Disclosure Act 2010 and the CCC’s requirements regarding the conduct of investigations.

The approval of either the Chancellor, Vice-Chancellor and President or the Chief Operating Officer must be obtained prior to the engagement of an external investigator for a workplace investigation regarding reasonably suspected fraud and or corrupt conduct. 

3.4.3    Referral to the CCC (generally)

Unless directed otherwise by the CCC, UQ will promptly refer complaints to the CCC for assessment where UQ reasonably suspects corrupt conduct. UQ will ensure it complies with sections 40, 44 and 48 of the Crime and Corruption Act 2001 and the Public Records Act 2002.

3.4.4    Confidentiality

UQ will treat all matters of reasonably suspected corrupt conduct (which can include fraud) confidentially. Where possible, UQ will protect personal information of the complainant in accordance with the Privacy Management Policy and, if applicable, the Public Interest Disclosure Policy. However, there may be some instances where the disclosure of personal information will be necessary to adhere to the principles of natural justice or as required by law.

3.4.5    Internal reporting

Staff are required to report financial losses to UQ’s Chief Financial Officer (CFO) and the Insurance Services unit in accordance with UQ’s Reporting of Losses Procedure

All reports and concerns of actual or reasonably suspected fraud and corrupt conduct are to be reported to the IIU. The IIU will liaise with the relevant supervisor or senior manager where appropriate.

The IIU is responsible for ensuring appropriate assessment and investigation of fraud and corrupt conduct matters to ensure compliance with additional external reporting requirements and for providing feedback to the discloser.

Internal Audit will report any identified or reasonably suspected cases of fraud and corrupt conduct to the IIU as soon as possible for further assessment.  Similarly, for consideration in the Internal Audit planning process the IIU will, at the conclusion of an investigation, inform Internal Audit of any identified systemic breakdown regarding internal controls.

The CFO and Insurance Services will report any reasonably suspected cases of fraudulent or corrupt practices to the IIU and vice versa. 

3.4.6    External reporting

UQ has a number of legislative obligations in relation to reporting fraud and corrupt conduct matters to external agencies. These obligations are summarised as follows:

Reporting Agency

Responsible University officer

Details to report

Crime and Corruption Commission

The Vice-Chancellor has nominated the Director, IIU, to be the CCC Liaison Officer.

Suspected corrupt conduct as defined by the Crime and Corruption Act 2001.

Reportable as soon as reasonable suspicion is reached, unless otherwise stated by the CCC.

Queensland Police Service

Director, IIU

 

Suspected criminal activity against the University.

See Note 1

Queensland
Auditor-General

Chief Financial Officer

Criminal offences involving material loss for property that is money, a loss of more than $500, or for other property, a loss valued by the accountable officer of the University at more than $5000.

See Note 1

Minister for Education

Chief Financial Officer

Criminal offences involving material loss for property that is money, a loss of more than $500, or for other property, a loss valued by the accountable officer of the University at more than $5000.

See Note 1

Note 1: Pursuant to s21(3) of the Financial and Performance Management Standard 2009 external reporting should occur as soon as practicable but no later than 6 months after the accountable officer has become aware of the loss. 

3.4.7    Disciplinary action

UQ will discipline members of staff that have engaged in fraud and/or corrupt conduct, notwithstanding their position and power in accordance with the Enterprise Agreement and other relevant policies and procedures.

3.4.8    Frivolous or vexatious complaints

UQ will take disciplinary action against member of staff for making complaints that are frivolous or vexatious or that intentionally makes false or misleading statements. Making such complaints or statements may be reasonably suspected to amount to corrupt conduct and subsequently referred to the CCC if necessary.  

3.4.9    Weaknesses in control

UQ will promptly address any deficiencies in controls or culture to prevent the recurrence of similar irregularities and to further reduce the risk of corrupt conduct.

3.4.10    Community awareness

To maintain public confidence and trust in UQ, information about UQ’s Fraud and Corrupt Conduct Policy and Procedures will be made accessible to key stakeholders such as contractors, suppliers and consultants.

4.0    Roles, Responsibilities and Accountabilities

4.1    Integrity and Investigations Unit

The Vice-Chancellor and President has authorised the Director, Integrity and Investigations Unit (IIU) to refer matters of reasonably suspected corrupt conduct to the CCC.

The IIU is responsible for:

  • undertaking a UQ-wide fraud and corrupt conduct risk assessment and ensuring appropriate controls are in place;

  • assisting and supporting other complaints management functions of UQ as directed;

  • managing and undertaking investigations and developing investigation frameworks associated with this procedure and the Fraud and Corrupt Conduct Policy; and

  • reporting on investigations and complaints and identifying trends.

4.2    Internal Audit

Internal Audit will report any cases identified as possible or reasonably suspected fraud and corrupt conduct to the IIU for further assessment. Similarly, for consideration in the Internal Audit planning process the IIU will, at the conclusion of an investigation, inform Internal Audit of any identified systemic breakdown regarding internal controls.

5.0    Monitoring, Review and Assurance

The Director, IIU is responsible for the promotion of this procedure and for ensuring that it is regularly reviewed for currency and effectiveness.

The Director IIU will continually monitor and review actions for the purpose of:

  • assessing compliance with this procedure and to demonstrate/confirm its effectiveness;

  • identifying, assessing and promptly addressing any deficiencies;

  • ensuring ongoing relevance of this procedure;

  • assessing effectiveness of controls; and

  • reporting through the Chief Operating Officer on weaknesses in controls as appropriate.

6.0    Recording and Reporting

The IIU will record all reported or detected incidents of fraud or corrupt conduct within its Complaints Management Database. 

The IIU will prepare and submit reports on current matters and trends involving fraud or corrupt conduct as required for statistical analysis and corrupt conduct prevention, and to the following parties as required or requested:

  • Issues Management Group

  • Vice-Chancellor’s Risk and Compliance Committee

  • Senate Risk and Audit Committee

  • the CCC

  • external auditors.

7.0    Appendix

Affiliates – academic title-holders, visiting academics, emeritus professors, adjunct and honorary title-holders, industry fellows and conjoint appointments.

Complaint – an expression of dissatisfaction with a product or service offered or provided by UQ or the conduct of UQ staff, affiliates, volunteers or students (in so far as their role at UQ), whether voiced by a member of the community, staff, affiliate, volunteer or a student.  In relation to corrupt conduct, a complaint includes information or a matter of reasonably suspected corrupt conduct.

Corrupt Conduct – under s15 of the CC Act there are two different types of corrupt conduct known
as ‘Type A’ and ‘Type B’:   

  • Type A involves conduct by any person that affects, or could affect, how officers from a
    Unit of Public Administration (i.e. the University) perform their functions or exercise their powers.
    Some common examples of Type A corrupt conduct include fraud (e.g. misuse of a corporate credit card), unauthorised release of information or nepotism in recruitment.

  • Type B involves conduct by any person that impairs, or could impair, public confidence in public administration.
    Type B corrupt conduct might include collusive tendering or dishonestly obtaining public funds or state assets. 

Each type of corrupt conduct has to satisfy three essential elements including that the conduct must be either a criminal offence or serious enough to warrant dismissal.  Further details about this essential criteria can be found at s15 of the CC Act and in the CCC’s guide 'Corruption in focus'.

Corruption – a broader term than corrupt conduct. Defined by Australian Standard 8001-2008 Fraud and Corruption Control as:

‘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’.

Enterprise AgreementThe University of Queensland Enterprise Agreement.

Fraud – defined by Australian Standard 8001-2008 Fraud and Corruption Control as:

‘Dishonest activity causing actual or potential financial loss to any person or entity including theft of moneys or other property by employees or persons external to the entity and where deception is used at the time, immediately before or immediately following the activity. This 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’. This definition of fraud can also encompass corrupt conduct.

Reasonably Suspects – under the CC Act 'reasonably suspects' means 'suspects on grounds that are reasonable in the circumstances'. The 'Corruption in focus' guide adds that for a suspicion to be ‘reasonable’, there needs to be more than bare or idle speculation and that, in essence, there must be some evidence sufficient for a reasonable person to suspect corrupt conduct.

Staff – continuing, fixed-term, research (contingent funded) and casual staff members.

Volunteers – members of the community who donate their services in a voluntary capacity to UQ without expectation of remuneration. Volunteers include those undertaking work on fundraising and community-oriented projects, tertiary students wishing to gain exposure to particular UQ functions, among others.

Custodians
Director, Integrity and Investigations Mr David Lavell
Custodians
Director, Integrity and Investigations Mr David Lavell