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B/8.6 Corruption and fraud control policy |
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8.6.1 Policy principles 8.6.1 Policy principlesQUT is committed to maintaining an organisational culture which ensures that effective corruption and fraud prevention is an integral part of all University activities and a core management capability, consistent with the QUT Code of Conduct ( B/8.1 ) and relevant legislation and in accordance with the Australian Standard 8001-2008 Fraud and Corruption Control. The University’s policy on corruption and fraud control is based on the following principles:
8.6.2 DefinitionsCorruption is defined in a practical way by AS8001-2008 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. It is further described by the Crime and Misconduct Commission (CMC) as behaviour that may involve fraud, theft, the misuse of position or authority or other acts that are unacceptable to an organisation and which may cause loss to the organisation, its clients or the general community. It may also include other elements such as breaches of trust and confidentiality. The behaviour need not necessarily be criminal. Fraud is defined by AS8001-2008 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 whether or not 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. Fraud can also be seen as a major subset of corruption and is a deliberate, intentional and premeditated dishonest act or omission acted out with the purpose of deceiving to gain advantage from a position of trust and authority. It includes acts such as theft, making false statements/representation, evasion, manipulation of information, criminal deception and misuse of University property or time. Maladministration is defined in the Whistleblowers Protection Act 1994 as an administrative action that is unlawful, arbitrary, unjust, oppressive, improperly discriminatory or taken for an improper purpose, and which substantially and adversely affects someone's interests. 8.6.3 Roles and responsibilities for corruption and fraud controla) Council Council approves policy and receives advice on the Corruption and Fraud Control Plan and Risk Assessments through Audit and Risk Management Committee as required. b) Audit and Risk Management Committee Audit and Risk Management Committee endorses QUT’s Corruption and Fraud Control Plan and Risk Assessments and reports to Council as required. c) Vice-Chancellor As the University’s chief executive officer, the Vice-Chancellor is responsible for the implementation of this policy through the Corruption and Fraud Control Plan and an effective internal control structure and policy (see A/2.6 ). d) Senior managers Senior managers are responsible in their organisational area for:
e) Managers of operational areas Managers are responsible in their operational area for:
f) All staff All staff have a responsibility to undertake their duties in accordance with the Code of Conduct ( B/8.1 ) and to promptly report any instances of fraudulent or corrupt activities to their supervisor. Further specific responsibilities for fraud and corruption control are detailed in the Corruption and Fraud Control Plan. 8.6.4 Implementation of corruption and fraud controlThe University has identified the following elements as critical to its successful control of corrupt and fraudulent activity. These elements are further detailed in the Corruption and Fraud Control Plan. a) Good corporate governance QUT’s Corporate Governance Framework ( A/1.1 ) is integral to the control and management of corruption and fraud. Corporate governance structures, such as the University’s Schedule of Authorities and Delegations and Council Procedure 1 - Committees, improve QUT’s transparency and accountability, consistent with sound business practices and compliance, and reduces the likelihood that it will suffer financial loss or damage to its reputation as a result of misconduct by its officers. b) Executive and management commitment The commitment of the Council, Vice-Chancellor and management at all levels of the University to the proactive prevention of corrupt or fraudulent activities in a systematic way is crucial to effective fraud and corruption control. c) Internal control structure Financial, administrative and information systems, and academic internal controls, are all essential requirements for corruption and fraud prevention. The University’s Internal Control policy ( A/2.6 ) states that individual managers are responsible for daily operations and for maintaining a cost-effective internal control structure within their organisational responsibility. Internal controls are subject to audit reviews by Assurance and Risk Management Services. d) University culture of ethical behaviour QUT values honesty, integrity and ethical behaviour and practices and is committed to maintaining a culture of high ethical standards and accountability in its teaching, research and community activities. Such a culture is reinforced with solid governance structures, management commitment, and relevant staff development and training. e) Reporting of and dealing with complaints All complaints of suspected corrupt or fraudulent behaviour should be reported in accordance with the University’s Code of Conduct and Corruption and Fraud Control Plan. f) Recruitment and development of staff QUT’s recruitment policies and practices underpin the prevention of corruption and fraud. Courses / seminars and presentations on the topics of ethics, corruption and fraud prevention and detection, and compliance obligations of individual staff members, are embedded into the University's ongoing staff induction, development, training and awareness programs as detailed in the Corruption and Fraud Control Plan. Related DocumentsCorruption and Fraud Control Plan MOPP A/1.3 Compliance policy MOPP A/2.6 Internal control policy MOPP B/8.1 QUT Code of Conduct MOPP B/8.2 Official misconduct MOPP B/8.5 Disciplinary action for misconduct and serious misconduct - senior staff MOPP B/8.3 QUT Whistleblowers Protection Management policy MOPP B/8.4 Academic and professional staff misconduct MOPP B/8.5 Disciplinary action for misconduct and serious misconduct – senior staff MOPP D/2.6 QUT Code of Conduct for Research MOPP Appendix 2 Council Procedure 1 - Committees Public Sector Ethics Act 1994 (Qld) Whistleblowers Protection Act 1994 (Qld) Crime and Misconduct Act 2001 (Qld) Queensland Criminal Code Act 1899 Financial Accountability Act 2009 (Qld) Financial and Performance Management Standard 2009 (Qld) Australian Standard: AS 8001-2003 Corporate Governance - Fraud and Corruption Control Modification History
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