A/1.3 Compliance policy

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1.3.1 QUT's commitment to compliance
1.3.2 QUT Compliance Program
1.3.3 Responsibilities for compliance
1.3.4 Compliance procedures, review and complaints handling
Related Documents
Modification History

1.3.1 QUT's commitment to compliance

As a public entity, QUT has a responsibility to identify and comply with all relevant obligations. Compliance means "adhering to the requirements of laws, industry and organisational standards and codes, principles of good governance and accepted community and ethical standards" (Australian Standard AS 3806 - 2006).

QUT's commitment to compliance is demonstrated by:

• the sponsorship and support from QUT Council and Audit and Risk Management Committee for the University's compliance program;
• the active engagement of the senior executive in the identification and management of compliance issues and risks; and
• the allocation of appropriate resources throughout the University to manage compliance obligations.

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1.3.2 QUT Compliance Program

QUT's compliance program is in conformance with Australian Standard AS 3806 - 2006 - Compliance Programs and is an important element of the University's corporate governance framework.

The compliance program aims to prevent, and where necessary, identify and respond to, non-compliance with the University's obligations under laws, regulations, codes and its own organisational standards. An important priority for the compliance program is to encourage a culture of valuing compliance with obligations, consistent with the profile of a good corporate citizen.

The compliance program's general aims are pursued through the following key elements:

• identification and management of the University's legal obligations in the Register of Compliance Obligations;
• allocation of responsibility to the relevant operational areas for ensuring compliance with obligations;
• risk rating obligations as part of the strategic planning and risk management processes on an annual basis to ensure awareness of the risk of non-compliance and to provide a measure of any exposure;
• the assessment of how well QUT meets its obligations, and where and how it could improve, including identification of any non-compliance and remedial action taken;
• promotion and training to staff and management on the importance of compliance with specific obligations, as well as commitment to compliance as an organisational value in line with the QUT Code of Conduct;
• fostering continuous improvement in compliance processes across QUT to ensure obligations are met; and
• regular reporting to Audit and Risk Management Committee.

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1.3.3 Responsibilities for compliance

a) All staff

In accordance with the QUT Code of Conduct, and the principle of diligence, all University staff should be conscientious in seeking to comply with relevant obligations in the course of their duties.

b) Registrar

The Registrar is responsible for implementation of the compliance program. The Registrar also sponsors University-wide compliance training programs.

c) Policy and Compliance Manager

The Policy and Compliance Manager is responsible for administering the compliance program, including:

• maintaining the Register of Compliance Obligations;
• coordinating annual compliance risk reporting through the University's strategic planning and risk management process;
• preparing annual reports to Audit and Risk Management Committee on major trends or issues identified during the annual reporting processes;
• developing educative training programs for relevant obligations to raise awareness of the University's obligations; and
• providing advice to responsible officers and other staff on compliance obligations and issues.

d) Responsible officers

Responsible officers are designated for all obligations, and are normally the head of the operational area allocated responsibility for ensuring compliance with a specific obligation. There may be multiple responsible officers for certain obligations.

Responsible officers are required to:

• confirm that they are seeking, in the course of their operational activities, to ensure monitoring of compliance with each obligation allocated to them, and how this is achieved;
• risk rate each obligation on an annual basis through the University's strategic planning and risk management process; and
• evaluate, at least annually, the risk treatments identified for each obligation, and report on any incidents of non-compliance and the remedial action taken to address them, including any ongoing non-compliance issues.

Responsible officers are expected to maintain a sound knowledge of their designated obligations, and should convey advice of new obligations or changes to existing ones to the Policy and Compliance Manager.

e) Senior managers

The management of compliance will chiefly occur within operational areas, and non-compliance will be dealt with through existing operational level management processes. However, compliance issues will on occasion necessitate an escalation to senior management because of the nature of the risk or resources involved. In these cases, it is the responsibility of senior managers to review the situation and implement remedial procedures to manage the risks in accordance with the University's Risk Management Framework.

At all times it is the responsibility of senior managers to remain aware of the compliance obligations allocated to operational areas under their supervision, and the designated responsible officer's management of these obligations.

f) Audit and Risk Management Committee

Audit and Risk Management Committee is responsible for ensuring that it receives an annual report and ad hoc reporting as required from the Policy and Compliance Manager, and that it identifies and requests follow-up action on any issues of concern.

g) QUT Council

QUT Council is responsible for approving the compliance policy and for ensuring that it receives adequate reporting on compliance from Audit and Risk Management Committee.

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1.3.4 Compliance procedures, review and complaints handling

a) Compliance procedures

Operational procedures relating to the compliance program can be found on the Compliance Program website.

b) Review

Responsible officers must ensure that procedures in place to manage compliance with obligations are regularly reviewed, as part of their continuous improvement processes.

The operation of the compliance program itself will be regularly reviewed by Assurance and Risk Management Services.

c) Complaints handling

Complaints about non-compliance, impacts of remedial action, or other issues arising from the compliance process are dealt with at the operational management level, through existing grievance procedures, Student Ombudsman's Office, or Whistleblowers legislation.

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Related Documents

Australian Standard AS 3806 - 2006 - Compliance programs

MOPP A/1.1 QUT Governance Framework

MOPP B/8.1 QUT Code of Conduct - Guidelines for Ethical Conduct

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Modification History

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