Corrupt Conduct Reporting Policy

Print Version *

Policy overview

• 1 Purpose
• 2 Scope
• 3 Policy Statement
• 4 Principles
• 5 References
• 6 Schedules
• 7 Policy Information

1 Purpose

To establish the principles for reporting suspected Corrupt Conduct.

2 Scope

This policy applies to information and matters received by the University that may involve Corrupt Conduct as defined in the Crime and Corruption Act 2001.

This policy does not cover a Complaint that involves a Council member or a Complaint that involves or may involve Corrupt Conduct of the Vice-Chancellor. See the Policy on Complaints Involving Council Members and the Corruption Complaints About the Vice-Chancellor Policy.

3 Policy Statement

The University acknowledges the management of Corrupt Conduct is integral to good governance and management practice.

The Vice-Chancellor must ensure the Crime and Corruption Commission is notified if there is a Reasonable Suspicion that Corrupt Conduct has occurred.

All University Members have an obligation to report any suspicions or allegations of Corrupt Conduct to:

• the Director (Integrity and Professional Conduct).

The obligation to notify the Crime and Corruption Commission has been assigned by the Vice-Chancellor to the Director (Integrity and Professional Conduct) allowing the person in this role to -

• receive or be notified of all Complaints raising possible Corrupt Conduct from external or internal sources;
• notify the Crime and Corruption Commission if they reasonably suspect that the Complaint involves, or may involve, Corrupt Conduct;
• prepare and retain complete and accurate records of any Decision to not notify the Crime and Corruption Commission of an allegation of Corrupt Conduct.

4 Principles

To comply with the Crime and Corruption Act 2001:

• Complaints can be anonymous and need not be in writing, although details of the Complaint should be recorded in writing by the receiving officer. It should also be noted that it may be difficult to resolve an anonymous Complaint unless contact details are provided in the event further information is required from a complainant to be able to pursue the Complaint;
• an Employee who becomes aware of or suspects Corrupt Conduct must immediately report it to an appropriate authority;
• the University may take disciplinary action against an Employee who fails to report acts or suspicions of Corrupt Conduct - a failure to report suspected corrupt conduct can in itself be Corrupt Conduct;
• the Crime and Corruption Commission will be notified as soon as there is a Reasonable Suspicion that Corrupt Conduct has occurred subject to any directions issued to the Vice-Chancellor by the Crime and Corruption Commission;
• no action will be taken in relation to a Complaint involving Corrupt Conduct before notifying the Crime and Corruption Commission, other than considering information in the direct knowledge of a relevant officer or in the University's records to decide whether there is a Reasonable Suspicion of Corrupt Conduct;
• a record will be made by the Director (Integrity and Professional Conduct) of a Decision that a Complaint, information or matter, about alleged Corrupt Conduct is not required to be notified to the Crime and Corruption Commission;
• no further action will be taken after notifying the Crime and Corruption Commission before being advised of their assessment decision and any recommendations or directions about how to Deal with the matter;
• a Complaint, information or matter involving Corrupt Conduct that is referred to the University by the Crime and Corruption Commission will be Dealt with in the way the Vice-Chancellor considers most appropriate, subject to the Crime and Corruption Commission's monitoring role;
• when an Employee makes an allegation about the conduct of another person which would, if proved, be Corrupt Conduct, the information may also be a Public Interest Disclosure under the Public Interest Disclosure Act 2010 and the Employee will be entitled to certain protections. For more details, refer to the Public Interest Disclosure Policy;
• a person who makes a Complaint that is Dealt with by the University must be given a response unless the person has not given their name and address or does not require a response, or if the response would disclose information the disclosure of which would be contrary to the public interest;
• the University will provide mandated training to ensure all University Members are made aware of their obligations contained in this policy;
• Managers should ensure all Employees under their supervision complete the mandated training and are aware of their obligations contained in this policy;
• the Director (Integrity and Professional Conduct) is responsible for the review of this document at least annually.

5 References

Corruption in focus: A guide to dealing with corrupt conduct in the Queensland public sector. (2020). Brisbane, Qld: Crime and Corruption Commission.

6 Schedules

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

7 Policy Information