Fraud and Corruption Management - Policy

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1. Purpose and Objectives

1.1 This policy is based upon the Australian Standard: Fraud and Corruption Control (AS8001:2008) and guidelines from the Crime and Misconduct Commission (CMC) "Fraud and corruption control: guidelines for best practice."

1.2 The University of Queensland recognizes that fraud and corruption management is an integral part of good governance and management practice.  The University has a zero-tolerance stance on fraud and corruption and is committed to maintaining an organisational culture which will ensure that effective prevention of fraud and corruption is an integral part of all university activities, consistent with its Code of Conduct and the law.

1.3 The University of Queensland is established under Queensland Legislation; it is a statutory authority, and as such falls within the jurisdiction of the CMC. Under the Crime and Misconduct Act any acts which could amount to official misconduct must be notified to the CMC, by the CEO.

1.4 The objectives of this policy are to

  • Foster an ethical culture throughout the organisation
  • Protect the University's interests, assets and reputation
  • Provide a transparent and coordinated approach to dealing with suspected fraud and corrupt activities
  • Encourage, support and protect persons who report suspected fraud and corruption.

2. Definitions, Terms, Acronyms

Definitions within this policy are as per the AS 8001:2008, UQ broadened definition denoted by (italics);

Fraud - dishonest activity causing actual or potential financial loss to any person or entity including theft of other moneys or other property by employees or persons external to the entity and whether or not deception is used at the time, immediately before or 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. 

CEO - for the purposes of the Crime and Misconduct Act the CEO at UQ is the Vice-Chancellor.

Corruption - dishonest activity in which a director (Senator), executive, manager, employee or contractor, or (student, or other member of the UQ community) of the entity acts contrary to the interests of the entity and abuses his/her position of trust in order to achieve some personal gain for him or herself or for another person or entity.

Official Misconduct - refers to any conduct by a public official, related to the official's duties, that is dishonest or lacks impartiality, involves a breach of trust, or is a misuse of officially obtained information. The conduct must amount to a criminal offence or be serious enough to justify dismissal. The CEO is obliged to report suspected official misconduct to the CMC.

3. Policy Scope/Coverage

This policy applies to all students, staff and Senators of the University, and its controlled entities.

4. Policy Statement

UQ is committed to the prevention of fraud and corruption within the University and its controlled entities. All members of the university community are expected to adopt, promote and demonstrate ethical behaviour through their work. This requires individuals to not only be responsible for their own behaviour but to support others in adopting ethical practices.

4.1 Fraud and corruption risk

UQ will maintain a University-wide Fraud and Corruption Risk Register. Organisational Units are also expected to consider Fraud and Corruption Risks as part of their own unit risk assessments.

4.2 Reporting and protected disclosures

Where any staff member is aware of or suspects fraudulent or corrupt activities they must report these suspicions immediately. Staff should do so in accordance with the Public Interest Disclosure Policy. Legislative protection is accorded to staff members who make disclosures under the Public Interest Disclosure Policy.

Staff members who intentionally give information that is false or misleading will not receive legislative protection.

Students may also report suspicions of fraudulent or corrupt activities and will also be provided protection.

The University will assess and investigate all allegations of fraud or corruption, and where official misconduct is suspected, these matters will be referred to the CMC.

All University officers who are involved in or become aware of an investigation into possible fraud or corruption must keep the details and results of any investigation confidential.

4.3 Responsibilities

4.3.1 Senate

Senate approves policy with respect to Fraud and Corruption Management, and receives advice on Fraud and Corruption Risk via the Risk Committee as required.

4.3.2 Vice-Chancellor

As CEO of the organisation the Vice-Chancellor is responsible for reporting fraud or corrupt activities, which may be considered official misconduct, to the CMC.

4.3.3 University Senior Management

The Vice-Chancellor and the executive management team are responsible for the implementation of this policy through an appropriate fraud and corruption control plan and an effective internal control structure.

4.3.4 Senior Management

Senior management are responsible within their organisational area to ensure:

  • controls and procedures are in place to prevent and detect any fraudulent or corrupt activities;
  • that they can identify and assess the risk of fraud and corruption;
  • staff are aware of the University's policy on fraud and corruption management, and their obligations for ethical conduct in their duties; and
  • encouragement of prompt reporting of any suspicions of fraud or corrupt activities.

4.3.5 All staff

Staff have a responsibility to undertake their duties ethically and in accordance with the Code of Conduct. Any staff member who suspects fraud or corrupt activity has a responsibility to report it, in accordance with the Public Interest Disclosure Policy.

4.4 Relevant legislation

The University of Queensland Act 1998

Crime and Misconduct Act 2001

Public Interest Disclosure Act 2010

Public Sector Ethics Act 1994

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