Director, Assurance, Risk and Integrity Services
Date of Next Review
QUT is committed to maintaining an organisational culture which ensures that integrity is an integral part of all University activities and a core management capability, consistent with the QUT Blueprint, the QUT value of Integrity, the QUT Staff Code of Conduct (B/8.1) which embed ethical behaviour and practices and relevant legislation and in accordance with the Crime and Corruption Commission Queensland – Corruption in focus.
The University’s policy on corruption and fraud control is based on the following principles:
- QUT operates in an environment in which ethical conduct is expected, encouraged and supported, with no tolerance for corrupt conduct, fraudulent activities or maladministration
- Officers of the University are placed in a position of trust and are required to maintain and enhance public confidence in the integrity of the University and to advance the common good of the University community
- The University will investigate and manage all reported cases of alleged fraud or corruption in accordance with its misconduct policies and procedures (B/8.5); relevant QUT enterprise agreements for academic staff and professional staff and/or criminal proceedings
- QUT will ensure that it has in place effective operational controls and procedures for the prevention and detection of corrupt and fraudulent activities, as summarised in QUT's Corruption and Fraud Control Plan and other documents, e.g. QUT Finance Manual.
This policy applies to all staff members, whether full-time, part-time, ongoing, fixed-term, casual or sessional. It also applies to the following members of the University community:
- members of QUT Council or other University committees whether they hold office by election, nomination or appointment
- visiting and adjunct academics, or other academic or research collaborators
- volunteers who contribute to or act on behalf of the University
- individuals who have been granted access to QUT property, services or infrastructure
- consultants and independent contractors undertaking services for QUT.
Risk and Audit Committee
|Vice-Chancellor and President||
|Senior managers (within their organisational area)||
|Managers of operational areas||
The University has identified the following elements as critical to its successful control of corrupt and fraudulent activity. These elements are further summarised in the Corruption and Fraud Control Plan.
The QUT Governance Framework (A/1.1) is integral to the control and management of corruption and fraud. Governance structures, such as the University’s Register of Authorities and Delegations (QUT staff access only) 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.
Executive and management commitment
The commitment of the Council, Vice-Chancellor and President 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.
All managers should ensure that they are familiar with the Corruption and Fraud Control Plan and that there are control and monitoring mechanisms in place consistent with the Plan within their organisational area of control.
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 audits and reviews by Assurance, Risk and Integrity Services.
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.
Reporting of and dealing with complaints
Independent complaint management
The University has engaged external and independent complaint management service called Your Call.
Staff have the option to utilise the existing internal pathways to lodge a complaint (e.g. with an appropriate supervisor or leader) or to make it directly to Your Call. If Your Call receive the complaint they will act as the intermediary at all times, receiving and forwarding communication between the complainant and QUT.
Your Call have protocols in place to protect the anonymity of staff making complaints, noting there may be limitations on the extent to which anonymous complaints can be fully investigated and/or resolved.
Importantly, Your Call will refer all matters back to QUT for resolution in accordance with this policy, where relevant, and updates on the complaint resolution process will be provided to Your Call for sharing with the complainant. Conflict of interest, Code of conduct and Confidentiality provisions apply to all those involved in handling complaints.
Recruitment and development of staff
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.
Corruption is defined in a practical way by AS8001-2021 as dishonest activity in which a person associated with an organisation (e.g. director, executive, manager, employee or contractor) acts contrary to the interests of the organisation and abuses their position of trust in order to achieve personal advantage for another person or organisation.
Fraud is defined by AS8001-2021 as dishonest activity causing actual or potential gain or loss to any person or organisation including theft of moneys or other property by persons internal and/or external to the organisation and/or where 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 for personal financial benefit. 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 Public Interest Disclosure Act 2010 as an administrative action that:
a) was taken contrary to law; or
b) was unreasonable, unjust, oppressive, or improperly discriminatory; or
c) was in accordance with a rule of law or a provision of an Act or a practice that is or may be unreasonable, unjust, oppressive or improperly discriminatory in the particular circumstances; or
d) was taken:
(i) for an improper purpose; or
(ii) on irrelevant grounds; or
(iii) having regard to irrelevant considerations; or
e) was an action for which reasons should have been given, but were not given; or
f) was based wholly or partly on a mistake of law or fact; or
g) was wrong.
MOPP A/1.3 Compliance
MOPP A/2.5 Risk management
MOPP A/2.6 Internal control
MOPP B/4.1 Recruitment and advertising
MOPP B/8.1 QUT Staff Code of Conduct
MOPP B/8.3 Public interest disclosure management
MOPP B/8.5 Disciplinary action for misconduct and serious misconduct – senior staff
MOPP B/8.7 Conflict of interest
MOPP B/12.1 Staff development policy
MOPP D/2.6 QUT Code for responsible conduct of research
MOPP Appendix 2 Council Procedure 1 - Committees
Corruption and Fraud Control Plan (QUT staff access only)
Enterprise Agreement (Academic Staff)
Enterprise Agreement (Professional Staff)
Australian Standard: AS 8001-2021 - Fraud and Corruption Control
Crime and Corruption Act 2001 (Qld)
Financial Accountability Act 2009 (Qld)
Financial and Performance Management Standard 2019 (Qld)
Public Sector Ethics Act 1994 (Qld)
Public Interest Disclosure Act 2010 (Qld)
Queensland Criminal Code Act 1899
|29.07.22||All||Director, Assurance, Risk and Integrity Services||Periodic review - minor editorial revisions|
|02.06.21||B/8.6.1||Vice-Chancellor and President||Administrative amendment to include a new external complaints process through an independent service provider (effective 16.06.21)|
|30.09.19||All||Director, Assurance and Risk Management Services||Periodic review - minor editorial revisions|
|05.02.15||All||Director, Assurance and Risk Management Services||Periodic review - minor revisions to reflect updates to Corruption and Fraud Control Plan|
|22.02.12||All||Audit and Risk Management Committee||Periodic review - policy revised to reflect Public Interest Disclosure Act 2010 definition of maladministration|
|20.08.08||All||Council||Revised policy (endorsed by Vice-Chancellor’s Advisory Committee 30.07.08 and Audit and Risk Management Committee 13.06.08)|