(1) Effective prevention, detection and responses to fraud and corruption are essential to protect the reputation and business objectives of the University. (2) This Framework defines fraud as a deliberate and dishonest act intended for financial or personal gain, as a major subject of corruption (see definitions at Section 4). (3) Staff, students, contractors, Senators, Members and other affiliates must ensure ACU funds are spent for their intended purposes; its information is secure; academic and research activity is conducted with honesty and integrity; and assets and resources are used appropriately to protect ACU’s interests and reputation. (4) Development of this Framework is based on based on Fraud and Corruption Control AS 8001:2021 (AS 8001:2021). (5) This Framework is supported by: (6) The purpose of the Framework is to: (7) Fraudulent or corrupt activity of any kind, including for the benefit of ACU, is expressly forbidden. ACU has zero tolerance for fraud and corruption. Staff and students are expected to conduct themselves in a manner consistent with the principles and values of ACU. (8) Table 1 outlines definitions for Fraud, Corruption and Misconduct (9) Fraud and corruption threats may be generated internally through students (e.g. deliberately compromising academic integrity), researchers (e.g. driven by grant applications or budgeting concerns / career advancement desires or / “publish or perish” mentality) or other staff who are either self-motivated or recruited by a third party to specifically exploit a potential, current or former privileged access. They may also be unintentional fraudsters such as students who may not understand or be aware of academic or research integrity expectations or who become complicit to a fraud unknowingly. (10) Fraud and corruption threats may be generated by external parties such as research collaborators, contractors, and third-party service or placement providers. (11) Cyber fraud covers a wide range of criminal activity. This can include: (12) Both individuals and companies suffer from the costly effects of cyber fraud within their networks. (13) International threats may arise due to ACU’s activities, programmes and dealings with countries offshore. Issues may include: (14) Foreign interference can occur when activities carried out by, or on behalf of a foreign actor, are coercive, covert, deceptive or corrupting and are contrary to Australia’s sovereignty, values and national interests. Foreign actors may seek to engage in foreign interference through efforts to alter or direct ACU’s research agenda, economic pressure, solicitation or recruitment of post-doctoral researchers and academic staff and cyber intrusions. (15) THis Framework is based on two key components: (16) Incidents of identified or suspected fraud and corruption incidents must be recorded in ACU’s Fraud Registers. Five Fraud Registers will be maintained. These Registers will be reviewed by the Director, Legal, Assurance and Governance with summarised reports provided to Audit and Risk Committee at each meeting. (17) This Framework is scheduled for review every five years or more frequently if appropriate. (18) For further assistance, please contact the Responsible Officer, Director, Legal, Assurance and Governance. (19) Unless otherwise indicated, this Framework will still apply beyond the review date.Fraud and Corruption Control Framework
Section 1 - Background
Top of PageSection 2 - Purpose
Top of PageSection 3 - Fraud and Corruption Statement
Section 4 - Definitions
Fraud, Corruption and Misconduct
Top of Page
Term
Definition
Fraud
Corruption
Academic Misconduct
Research Misconduct
Section 5 - Sources of fraud and corruption
Internal
External
Cyber
International
Section 6 - Roles and Responsibilities
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Who
Fraud and Corruption Control Responsibilities
Senate
Senate Standing Committee
Audit and Risk Committee
Academic Board
Vice-Chancellor and President
Provost
Chief Operating Officer and Deputy Vice-Chancellor
Chief Financial Officer
Deputy Vice-Chancellor (Research and Enterprise)
Human Research Ethics Committee
Academic Registrar and Director, Student Administration
Director, Legal, Assurance and Governance
General Counsel
Chief People Officer
Chief Marketing Officer
Chief Information and Digital Officer
National Manager, Advancement and Alumni
Management Levels
1–5
All staff
Credit Card Holders
Section 7 - Fraud and Corruption Control Framework
Top of PageSection 8 - Fraud and Corruption Framework – Structural Foundations
Top of Page
Framework
STRUCTURAL FOUNDATIONS
ACTIVITY
Leadership
Senate is committed to the highest ethical standards such that they support and imbue the ACU Strategic Plan and ACU Mission, Identity and Values and vision.
Members of the Senior Executive place the utmost importance on effective fraud control and ethical behaviour in all ACU’s operations as they relate to students, staff members, education and research quality and integrity and interactions with all other stakeholders and wider ACU community.
ACU leaders acknowledge that the “tone is set from the top”.
Culture
Underpinning the success of all ACU fraud and corruption control strategies is a strong ethical culture that values and supports honesty, trust, transparency and fair dealings.
Code of Conduct for Staff
It speaks to issues around honesty and integrity which are “fundamental principles of the University as an institution devoted to the pursuit of excellence in student learning and teaching, research and service, and to respecting the value and dignity of each person.”
Importantly it points to important aspects of Fraud including “Conflicts of Interest” and Gifts and Benefits.
Training and Awareness
Formal and informal training and awareness programs provide staff members with:
Ethical Employment Practices
ACU acknowledges that commitment to ACU Mission, Identity and Values is best served when staff members feel appropriately valued.
Staff member investment reduces the risk of internal fraud.
Capability Development
ACU supports a strong and positive culture through its Capability Development Framework (“CDF”).
The CDF is one of several frameworks and standards that express the University’s expectations of the conduct, capability, participation and contribution of staff (such as the Code of Conduct for Staff, Research Code of Conduct, the Learning for Life Framework and the Academic Performance Matrices).
The CDF applies to everyone. It enables a whole-of-organisation approach to develop and strengthening capability, and it is part of the ongoing investment by the University in the professional development of our staff. The CDF enables a clear view of the competencies that support achievement of excellence.
It supports conversations between staff and supervisors in identifying professional development opportunities, both to strengthen capability in the current role and understand expectations at the next level.
Governance
Corporate Structure
ACU’s governance structure supports fraud and corruption control at the strategic, academic and operational levels.
Risk Management Accountability - Three Lines of Defence Model
This responsibility is imbued not only within the Code of Conduct for Staff, policy compliance and employment agreements but also within the Three Line of Defense model which ACU has adopted with regards to risk and control management.
Roles and Responsibilities
Fraud and corruption control are a responsibility of every staff member.
Specific responsibilities for fraud and corruption control within the University however exist and are detailed in Section 6.
Communications and Protections
The University supports staff members through its Protected Disclosures Policy and Protected Disclosures Procedure for reportable conduct as well as through its Discrimination and Harassment Policy.
Policy and Procedures
Legislation
ACU complies with all relevant legislation as it relates to its Australian and international operations.
Section 9 - Fraud and Corruption Framework – Strategies
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Framework
Strategy
Activity
Assessment
Under the ERMF, all risks relating to fraud and corruption must be captured, assessed, responded to and monitored on an ongoing basis.
Prevention
Review and Ongoing Monitoring of ACU’s Fraud and Corruption Control Framework Foundations
ACU regularly reviews and monitors the foundations that underpin its Fraud and Corruption Control Framework. These reviews serve to highlight and action critical weaknesses such as staff disengagement or dissatisfaction, breakdowns in communications, distrust, and other issues that can lead to a fracture in ethical commitment. They also serve to provide transparent feedback to staff as part of the ongoing capabilities and development programme.Regularly review the Framework with consideration to information and feedback provided through:
Regularly review and confirm operation of key financial control processes including:
Office of Research Services and Research Finance Grants team regularly review and confirm operation of key financial control processes.
Detection
Internal Controls
In order to detect fraud and corruption, a robust internal control environment exists within the University.
This includes but is not limited to reconciliations, budgets, approvals and authorities, control self-assessments, and reporting for example.
Internal Audit
ACU maintains an outsourced Internal Audit Programme to provide an independent and objective assurance of ACU operations and activities.
Internal Audit provides a disciplined, systematic risk-based approach to detecting fraud and corruption risk and provides recommendations for strengthening the fraud control environment through consultation and reporting back to review sponsors, the Assurance Unit and the Audit and Risk Committee (ARC).
External Audit
External Audit is responsible for conducting an annual audit (and/or ad hoc reviews upon request) of the University’s financial statements. External Audit consider whether the accounts are true and fair or whether material misstatements exist.
Protected Disclosures
ACU is committed to ensuring that staff members and other identified stakeholders within the wider ACU community are protected upon making fraud and corruption disclosures.
Escalation and reporting
In order to ensure detected frauds and environment control weaknesses cannot be overlooked or underplayed, a quarterly de-identified report of all fraudulent activity must be provided to the Vice-Chancellor and President, the Academic Board (Academic and Research related only) and the ARC.
Response
Disciplinary Actions
The University has zero tolerance for fraud and corruption activity.
Should fraud or corruption activity be identified and confirmed, the University will follow its documented disciplinary procedures as outlined in the ACU Staff Enterprise Agreement 2022-2025, the Code of Conduct for Staff, the Student Academic Integrity and Misconduct Policy, the Research Code of Conduct and the Research Complaints and Investigations Procedure.
Where appropriate, fraud or corruption activity will be reported to external authorities for investigation and action.
Insurance and Asset Recovery
ACU holds a fidelity guarantee insurance policy to protect against the financial consequences of fraud by a staff member.
This obligation is required under AS 8001-2008.
ACU also holds insurance to protect against losses that result from cyber security breaches.
If external parties instigate a fraud against ACU, asset recovery may be pursued via civil or criminal action.
In cases where there is an opportunity to make a financial recovery from a person or company convicted of fraud, the decision to pursue this perpetrator will be made by the relevant officer in accordance with the Delegations of Authority Policy and Register.
Analysis of Control failures
ACU will conduct analysis of control failures and will ensure that learnings occur at the organisational level. ACU will strive for continuous improvement to strengthen and extend the foundations of its Fraud and Corruption Control Framework as well as its strategies to assess, prevent, detect and investigate potential and actual fraud.
Section 10 - Fraud Registers
Top of Page
Fraud Register
Responsibility
Academic Integrity
Provost, supported by Academic Registrar and Director, Student Administration and Academic Integrity Team.
Research Integrity
Deputy Vice-Chancellor (Research and Enterprise)
Financial
Chief Financial Officer
Human Resources
Chief People Officer
Information Technology
Chief Information and Digital Officer
Section 11 - Review
Section 12 - Further assistance
Section 13 - Review
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The Code of Conduct for Staff establishes the standards of behaviour expected from all staff members.
The reference to honesty in the Code of Conduct for Staff encourages readers to act lawfully and with integrity.
All staff at ACU have a responsibility for acting ethically.
The Code of Conduct for Staff encourages staff members to be “courageous” in actions relating to issues of ethical decision making.
The Research Code of Conduct and Research Complaints and Investigations Procedure provide guidance and direction with regards to research integrity
Staff are encouraged to report concerns of fraud to their supervisor. In matters of potential research integrity breaches, report concerns to the Research Ethics and Integrity Unit or Research Integrity Advisor. In the event the Supervisor is the subject of this concern, staff are encouraged to speak to another more senior manager or disclose the matter in accordance with the Protected Disclosures Policy and Protected Disclosures Procedure.
Commentary on fraud exists by implication in the Code of Conduct for Staff and other key governance documents including but not limited to the Misconduct and Serious Misconduct Policy, Research Code of Conduct, as well as Research Complaints and Investigations Procedure.
Compliance with policy and procedure is mandatory and is subject to not only supervisor and management oversight, but also ongoing substantive and qualitative testing and reporting via the ”Three lines of defense” model.
Identifying Sources of Threats
Understanding sources of fraud and corruption threats is important particularly given the breadth of ACU operations. Strategies need to be in place and agile where necessary, in order to preempt or respond to misconduct. Appendix B lists potential sources of fraud and corruption.
Risk Management Cycle
ACU has adopted a risk-based approach to managing fraud and corrupt practices through its policy and procedures and via its Enterprise Risk Management Framework (ERMF).
Delegated Authorities
The University maintains its delegated authorities to ensure that correct approval for all activities conducted within ACU is consistent and authorised in line with Senate's determinations.
Financial Control
Checks and balances are built into existing financial and financially implied processes.
ICT Security and Physical Access Control
ACU has a detailed set of cyber security protocols and processes aimed at reducing ACU exposure to cybercrime.
Disclosures of Interest
ACU requires staff with relevant interests to disclose directorships, secretaryships and partnerships. Any other conflicts of Interest must also be disclosed.
Suspected Fraud Response and Investigation training
Key staff responding to suspected fraud and involved in fraud investigations are provided with specific training as part of the capabilities and development framework.
Third party fraud and corruption prevention
Contractors, suppliers, research collaborators and practical placement providers are subject to a structured risk based due diligence process.
Data Analytics and Monitoring
Sophisticated data analytics provides ACU with metrics and reporting against which variance analysis and performance evaluations can be regularly conducted.
Fraud Database / Registers
The University maintains fraud and corruption databases / registers containing reports of suspected misconduct or actual fraud including actions taken and outcomes.
Investigation
ACU provides direction for investigations related to identifications of potential fraud and corruption through documented policies, procedures and processes. These include:
External Investigation
In some circumstances external investigation of reported or detected fraud and corruption may be required.