Fraud and Corruption Management Policy

Policy overview

1 Purpose

To provide the framework to sustain an organisational culture resistant to Fraud and Corruption.

2 Scope

This policy applies to University Members.

3 Policy Statement

The University recognises Fraud and Corruption control is a key component of its integrity framework to mitigate the risk of unacceptable costs or losses associated with its operations.

Consistent with the law and the University's Code of Conduct, the objectives of the integrity framework are to:

  • foster ethical conduct throughout the University and its activities;
  • protect the University's interests, assets and reputation;
  • uphold a transparent integrated approach to prevent, detect and respond to Fraud and Corruption matters; and to
  • encourage, support and protect individuals who report suspected Fraud and Corruption activity.

To that end, the University adopts a zero-tolerance approach to Fraud and Corruption across all of the University's activities. This requires University Members to not only be responsible for their own behaviour but to support others to embrace ethical practice.

4 Principles

  1. Mitigation of Fraud and Corruption risk can only occur through the development of a Fraud and Corruption control framework involving a high level of governance and management direction.
  2. Effective control involves identifying the University's key Fraud and Corruption risks.
  3. To safeguard all aspects of the University's performance, an integrated control framework will be established to minimise and manage Fraud and Corruption risk.
  4. Monitoring and review of the internal controls should be a normal part of the management process that can inform the development of an independent review and audit program.
  5. Robust mechanisms will be established to encourage and support the reporting of suspected cases of Fraud or Corruption by individuals from within and outside the University, including anonymous reports.
  6. All reasonable measures will be taken to support a person who discloses suspected Fraud and Corruption, and provide protection from reprisal as a result of making a disclosure.
  7. Allegations of Fraud or Corruption will be assessed, and where the pertinent criteria are established, a matter will be reported to the relevant external body including the:
    1. Crime and Corruption Commission [section 38, 48A of the Crime and Corruption Act 2001]
    2. Queensland Ombudsman [sections 33, 58 of the Public Interest Disclosure Act 2010]
    3. Queensland Audit Office [section 21(3) of the Financial Management Practice Manual]
    4. Queensland Police Service [section 21(3)(c) of the Financial Management Practice Manual]
  8. Procedures defining the roles, responsibilities, authority and powers delegated to management and investigators will be used to determine the investigation approach commensurate with the nature and seriousness of a matter.
  9. The Employee induction and annual refresher program will include addressing Fraud and Corruption risk topics.

5 References

Crime and Corruption Commission Queensland (2018). Fraud and Corruption Control: Best Practice Guide. Crime and Corruption Commission (Queensland).

6 Schedules

This policy must be read in conjunction with its subordinate schedules as provided in the table below.

7 Policy Information

Accountable Officer

Vice-Chancellor

Responsible Officer

Deputy Vice-Chancellor (Enterprise Services)

Policy Type

Governance Policy

Policy Suite

Fraud and Corruption Management Procedure

Subordinate Schedules

Approved Date

9/3/2020

Effective Date

9/3/2020

Review Date

9/3/2023

Relevant Legislation

Crime and Corruption Act 2001

Crime and Misconduct Commission - Fraud and corruption control: Guidelines for best practice

Financial Accountability Act 2009

Financial and Performance Management Standard 2019

Information Privacy Act 2009

Public Sector Ethics Act 1994

Right to Information Act 2009

Public Interest Disclosure Act 2010

Standard AS8001-2008: Fraud and Corruption Control

USQ Enterprise Agreement

Related Policies

Code of Conduct Policy

Privacy Policy

Public Interest Disclosure Policy

Risk Management Policy and Procedure

Related Procedures

Disciplinary Action for Misconduct or Serious Misconduct Procedure

Related forms, publications and websites

Financial Services Policies and Procedures

Definitions

Terms defined in the Definitions Dictionary

Corrupt Conduct

Defined in section 15 of the Crime and Corruption Act 2001....moreDefined in section 15 of the Crime and Corruption Act 2001.

Corruption

See Schedule 2 of the Crime and Corruption Act 2001....moreSee Schedule 2 of the Crime and Corruption Act 2001.

Council

Council means the governing body, the University of Southern Queensland Council....moreCouncil means the governing body, the University of Southern Queensland Council.

Employee

A person employed by the University and whose conditions of employment are covered by the USQ Enterprise Agreement and includes persons employed on a continuing, fixed term or casual basis. Employees also include senior Employees whose conditions of employment are covered by a written agreement or contract with the University....moreA person employed by the University and whose conditions of employment are covered by the USQ Enterprise Agreement and includes persons employed on a continuing, fixed term or casual basis. Employees also include senior Employees whose conditions of employment are covered by a written agreement or contract with the University.

Fraud

Fraud is conventionally characterised by deliberate deception to facilitate or conceal the misappropriation of assets, tangible or intangible. Matters will be assessed against the Criminal Code Act 1899....moreFraud is conventionally characterised by deliberate deception to facilitate or conceal the misappropriation of assets, tangible or intangible. Matters will be assessed against the Criminal Code Act 1899.

Fraud Investigation

A Fraud Investigation is a search or collation of evidence connecting or tending to connect a person with conduct that infringes criminal law or the policies of the University....moreA Fraud Investigation is a search or collation of evidence connecting or tending to connect a person with conduct that infringes criminal law or the policies of the University.

Public Interest Disclosure

A public interest disclosure is a disclosure under Chapter 2 of the Public Interest Disclosure Act 2010 and includes all information and help given by the discloser to a Proper Authority for the disclosure....moreA public interest disclosure is a disclosure under Chapter 2 of the Public Interest Disclosure Act 2010 and includes all information and help given by the discloser to a Proper Authority for the disclosure.

Student

A person who is admitted to an Award Program or Non-Award Program offered by the University and is: currently enrolled in one or more Courses or study units; or not currently enrolled but is on an approved Leave of Absence or whose admission has not been cancelled....moreA person who is admitted to an Award Program or Non-Award Program offered by the University and is: currently enrolled in one or more Courses or study units; or not currently enrolled but is on an approved Leave of Absence or whose admission has not been cancelled.

University

The term 'University' or 'USQ' means the University of Southern Queensland....moreThe term 'University' or 'USQ' means the University of Southern Queensland.

University Members

Employees of the University whose conditions of employment are covered by the USQ Enterprise Agreement whether full time or fractional, continuing, fixed-term or casual, including senior Employees whose conditions of employment are covered by a written agreement or contract with the University; Members of the University Council and University Committees; Visiting and adjunct academic...moreEmployees of the University whose conditions of employment are covered by the USQ Enterprise Agreement whether full time or fractional, continuing, fixed-term or casual, including senior Employees whose conditions of employment are covered by a written agreement or contract with the University; Members of the University Council and University Committees; Visiting and adjunct academics; Volunteers who contribute to University activities or who act on behalf of the University; Individuals who are granted access to University facilities or who are engaged in providing services to the University, such as contractors and consultants, where applicable.

Definitions that relate to this policy only

Other Definitions

Readers should also refer to the University Code of Conduct and the Enterprise Bargaining Agreement as an additional glossary resource.

Keywords

Fraud, Corruption

Record No

13/329PL

Complying with the law and observing Policy and Procedure is a condition of working and/or studying at the University.

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