Policy and Compliance Manager, Governance and Legal Services
Date of Next Review
1.3.3 Roles and responsibilities
1.3.4 Compliance Management System
1.3.5 Non-compliance and reporting
QUT is committed to the management of its compliance obligations as an integral and embedded part of all its activities. Effective management of QUT’s compliance obligations, through a risk-based approach, ensures that the University's strategic direction and corporate objectives are pursued in a lawful and sustainable manner.
Consistent with principles of good governance, QUT has a responsibility to identify and comply with all relevant laws, regulations and other externally imposed requirements, e.g. higher education standards or codes of relevant industry or regulatory bodies. QUT achieves this through the implementation of a University-wide compliance management system based on ISO 19600:2014: Compliance management systems.
The QUT compliance management system applies to all QUT activities to which external compliance obligations are relevant.
Vice-President (Administration) and University Registrar
|Primary responsible officer||
Is the senior officer with accountability, responsibility and authority for coordination and management of appropriate compliance risk management activities for their particular compliance obligation(s), including to:
|Secondary responsible officers||
|Director, Governance and Legal Services||
|Risk and Audit Committee||
Key elements of QUT's Compliance Management System are the:
- identification and management of the University's obligations in a Register of Compliance Obligations, taking account of the purpose and objectives of the University and internal and external issues and stakeholders
- allocation of roles, accountability, responsibility and authority to individuals within the relevant operational areas for ensuring appropriate compliance risk management of obligations
- risk assessment and risk rating of obligations, in particular, as part of the annual planning process
- development of actions integrated into operational requirements, processes and procedures to address or mitigate compliance risks in a proportional way reflecting the level of compliance risk exposure
- commitment to compliance as an organisational value in line with the QUT Staff Code of Conduct (B/8.1)
- promoting awareness of obligations and training of staff on compliance with specific obligations
- 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
- fostering continuous improvement in compliance risk management across QUT to ensure compliance obligations are met
- regular reporting to Risk and Audit Committee.
The Compliance Management System (QUT staff access only) provides detailed information on the management of compliance obligations, the compliance risk management process, the roles and responsibilities of key stakeholders, and documentation and reporting requirements.
At the time of occurrence, all incidents of non-compliance must be assessed. Where a non-compliance incident is assessed as having a consequence that is higher than insignificant (as described in the Enterprise Risk Consequence Matrix), the issue must be reported to the primary responsible officer. This officer will determine if adjustments to compliance procedures and risk treatments are required, and whether an ad hoc report should be made to Risk and Audit Committee.
The primary responsible officer is also required to oversee and monitor any remedial action or adjustments to compliance risk management activities (including policies, procedures and processes) which may be required in light of the non-compliance incident.
A summary of all incidents of non-compliance must be included in annual reporting.
Compliance risk management is the program of activities to address or mitigate compliance risk, including the establishment of culture, policy, procedures and processes.
Compliance risk is the risk of exposure to legal or financial penalties or other material losses (including reputational damage) due to a failure to prevent, detect or reduce the undesired or unacceptable effects of non-compliance with external laws, regulations and other externally imposed requirements.
Refer to Appendix 3 Schedule of Authorities and Delegations (C004, VC001, VC002, VC003, VC148, VC171, VC189, VC190).
MOPP A/1.1 QUT Governance Framework
MOPP A/2.5 Risk management
MOPP B/8.1 QUT Staff Code of Conduct
Enterprise Risk Management Framework (QUT staff access only)
Enterprise Risk Management Procedure (QUT staff access only)
Enterprise Risk Consequence Matrix (QUT staff access only)
International Standard ISO19600:2014 Compliance management systems
QUT Register of Compliance Obligations (QUT staff access only)
|25.05.20||All||Director, Governance and Legal Services||Periodic review – modernised template and minor editorial changes only|
|15.06.16||All||Council||Revised policy following review of compliance program|
|20.02.15||All||Policy and Compliance Manager||Periodic review - minor editorial changes only|
|25.08.10||All||Council||Periodic review - minor editorial changes only|
|18.07.07||All||Council||Revised policy (endorsed by Audit and Risk Management Committee 20.06.07)|