B/8.6 Corruption and fraud control

Policy Owner	Director, Assurance, Risk and Integrity Services
Approval Date	29/07/2022
Approval Authority	Council
Date of Next Review	01/08/2025

8.6.1 Purpose
8.6.2 Application
8.6.3 Roles and responsibilities
8.6.4 Implementation of corruption and fraud control
8.6.5 Definitions
Related Documents
Modification History

8.6.1 Purpose

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.

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8.6.2 Application

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.

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8.6.3 Roles and responsibilities

Position	Responsibility
Council	approves policy and receives advice on the Corruption and Fraud Control Plan through Risk and Audit Committee as required
Risk and Audit Committee	endorses the Corruption and Fraud Control Plan including the risk profile and reports to Council as required
Vice-Chancellor and President	implements this policy through the Corruption and Fraud Control Plan and an effective internal control structure and policy
Senior managers (within their organisational area)	establish and monitor controls and procedures for prevention and detection of any fraudulent or corrupt activities, in accordance with Corruption and Fraud Control Plan identify risk exposures to corrupt and fraudulent activities and ensure that regular assessment of the risks and controls are undertaken reinforce the requirement for ethical conduct by staff and other officers and encourage the prompt reporting of any instances of fraud, corrupt conduct or maladministration ensure that all staff are aware of the University’s policy on corruption and fraud control, and their obligations for ethical conduct in their duties, including completing the General Required Training every two years
Managers of operational areas	display a positive attitude towards compliance with laws, rules and regulations ensure that they are aware of indictors of fraudulent and corrupt conduct, and respond appropriately to such indicators establish adequate internal controls to provide for the security and accountability of university resources to prevent or reduce the opportunity for fraudulent and corrupt activities
All staff	undertake their duties in accordance with the QUT Staff Code of Conduct promptly report any instances of fraudulent or corrupt activities to their supervisor undertake the General Required Training online module every two years

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8.6.4 Implementation of corruption and fraud control

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.

Good governance

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

All complaints of suspected corrupt or fraudulent behaviour should be reported in accordance with the QUT Staff Code of Conduct (B/8.1) and Corruption and Fraud Control Plan (QUT staff access only).

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

QUT’s recruitment and staff development policies (B/4.1 and B/12.1) 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.

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8.6.5 Definitions

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.

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Modification History

Date	Sections	Source	Details
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)
16.07.03	All	Council	New policy

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