(1) This Policy covers non-education external partnerships, emphasising the University's commitment to establishing and nurturing beneficial partnerships that are characterised by transparency, alignment with the ACU Mission, Identity and Values, strategic importance, mutuality, and robust and sustainable relationships. By setting standards, the Policy ensures that all partnerships, whether international or local, adhere to the same high standards, supporting the University’s strategic objectives and fostering an ecosystem of collaboration that is both secure, sustainable, and conducive to innovation and excellence. The Policy particularly facilitates and secures the international research partnerships that are an essential element of our Mission to create and preserve knowledge globally, engaging in and helping to increase the free exchange of knowledge and expertise across borders and cultures. (2) In this context, the Policy aims to ensure that the University has a robust framework for managing potential risks related to external partnerships, including ensuring compliance with Australian Government law and regulations (including sanctions) and by minimising the potential for foreign interference and harm (e.g., harm associated with dual use technology). This policy framework therefore aims to advance the University’s partnership ambitions in accordance with the University’s stated Risk Appetite Statement. (3) This Policy applies to all members of the University community, including staff and affiliates involved in external collaborations. This Policy covers all forms of non-Education external engagement, including research partnerships, commercial partnerships, joint ventures, and any other activities involving domestic or foreign entities. (4) This Policy only applies to partnerships that are not related to education (e.g., research and / or enterprise). For education partnerships (including those involved in research training) please see the Third Party and Educational Partnerships Policy. (5) In this Policy, the following terms are used as defined: (6) Mission and Vision Alignment: All collaborations must be aligned with the Australian Catholic University’s Mission and with Vision 2033. Partnering is critical to achieving the Mission of the University provided those partnerships are based on trust, mutual benefit, value alignment, openness and transparency. (7) Quality: All collaborations must be founded on a commitment to the production of high-quality outcomes and outputs, alignment to University KPIs and any additional mutually developed KPIs that underpin the partnering. (8) Compliance: All collaborations must comply with relevant Australian and foreign laws, including but not limited to the Defence Trade Controls Act 2012 (Cth), the Autonomous Sanctions Act 2011 (Cth), the Autonomous Sanctions Regulations 2011 (Cth), and Australia’s Foreign Relations (State and Territory Arrangements) Act 2020 (Cth), as well as all relevant ACU policies and procedures. (9) Transparency: The University commits to conducting its external collaborations transparently, ensuring clear documentation and reporting of activities, especially those involving sensitive technologies or dual-use research. Where a collaboration requires an non-disclosure agreement, transparency will flow through appropriate governance channels that allow for appropriate oversight while respecting requirements for confidentiality. (10) Due Diligence: Due diligence will be conducted for all collaborations to identify and mitigate risks related to Mission and value misalignment, foreign interference, sanctions, modern slavery, money laundering and other financial risk, and compliance with dual-use regulations. (11) Risk Management: The University will implement effective risk management strategies to protect its Mission and values, academic freedom and integrity, quality of research outputs, reputation, and financial interests. (12) Ethical Standards: All collaborations must adhere to the highest ethical standards, respecting intellectual property rights, academic freedom, and the University's values and promoting diversity, equity, and inclusion. (13) To safeguard against foreign interference, the University will: (14) In compliance with the Australia’s Foreign Relations (State and Territory Arrangements) Act 2020 (Cth), the University will: (15) The University recognises the importance of managing research with dual-use potential and complying with Australian sanctions laws. Therefore, it will: (16) The University is committed to conducting its operations and partnerships in an ethical and responsible manner, free from any involvement in modern slavery, money laundering, or other financial crimes. To uphold this commitment, the University shall implement robust due diligence processes to assess potential risks of modern slavery, money laundering, and other financial crimes in its supply chains, operations, and partnerships with external stakeholders consistent with the ACU Modern Slavery Statement. (17) ACU may only enter into partnership agreements after due diligence has been conducted. The due diligence requirements for specific agreement types are outlined in the Third Party and Educational Partnerships Procedure. (18) The Approver (Delegate) must be satisfied as to: (19) For international agreements: (20) High-risk collaborations will require approval from a member of the Vice-Chancellor's Advisory Committee. (21) The University will provide up-to-date training and resources to staff and students involved in international collaborations to ensure they are aware of their obligations under this Policy and relevant laws and regulations. (22) All continuing and fixed-term staff and Higher Degree by Research students must undertake Foreign Interference Awareness Training. (23) Staff with delegation to approve collaboration or who make decisions about collaborative projects must also undertake Due Diligence training. (24) In accordance with the Policy Development and Review Policy, this Policy is scheduled for review every (3) years. (25) The University will establish mechanisms to monitor compliance with this Policy and related legal requirements. (26) Any breaches of this Policy or relevant laws will be addressed promptly, and corrective actions will be taken. (27) For related legislation, policies, procedures and guidelines and any supporting resources, please refer to the Associated Information tab.Non-Education External Collaboration Policy
Section 1 - Purpose
Section 2 - Scope / Application
Section 3 - Terms / Definitions
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Term
Definition
Dual Use
Dual-use refers to items, including goods, software, technologies, and related services, that have both civilian applications and military, terrorism, weapons of mass destruction, or law-enforcement-related applications. The exporting of dual-use items, including through academic mediums (such as international publication, presentation, and collaboration), may require an export permit, which can be granted by Defence Export Controls, a branch of the Department of Defence.
Foreign Arrangements
A foreign arrangement is a written agreement, contract, understanding, or undertaking between an Australian State / Territory entity, or an Australian public university, and a foreign entity, whether legally binding or not. This includes collaborations with foreign universities and research institutions. Arrangements with foreign government entities and non-autonomous organisation require registration with the Department of Foreign Affairs & Trade.
Foreign Influence
Foreign influence refers to efforts by foreign governments, organisations, or individuals to sway or impact Australian policies, decisions, or activities. As the Department of Home Affairs states: “It is important to distinguish foreign interference from foreign influence. All governments, including the Australian Government, seek to influence issues of importance to them. Australia is not concerned with foreign influence activity that is open and transparent and that respects our people, society and systems.” (see Defining Foreign Interference)
Foreign Interference
Foreign interference occurs when activities carried out by, or on behalf of, a foreign power are coercive, corrupting, deceptive, or clandestine, and contrary to Australia’s sovereignty, values, and national interests. It involves attempts to covertly or improperly interfere in Australian society to advance foreign strategic, political, military, social, or economic goals.
Non-autonomous organisation
A non-autonomous organisation refers to an entity that does not operate independently or make decisions solely based on its own governance structures, policies, or interests. Instead, its operations, decision-making processes, or policies are significantly influenced, directed, or controlled by external entities such as foreign governments. This influence can compromise the organisation's ability to act independently and may align its activities with the interests or directives of the controlling entity rather than its own or its stakeholders’ interests.
Section 4 - Policy Statement and Principles
Principles
Foreign Interference
Foreign Arrangements
Dual Use and Sanctions
Financial Basis for Relationship
Due Diligence and Risk Assessments
Due Diligence Process
Approval Process
Training and Awareness
Section 5 - Review
Section 6 - Duration and Review of Agreements
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Section 7 - Roles and Responsibilities
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Section 8 - Associated Information
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Agreement Type
Duration
Monitoring
Within Australia
The maximum duration will be 5-years if deemed low risk following due diligence and risk assessment.
A shorter period of 1-2 years and enhanced monitoring will be required where the collaborator is considered higher-risk.
Monitoring by the Foreign Interference and Transparency Committee.
International
The maximum duration will be 5-years if deemed low risk following due diligence and risk assessment.
A shorter period of 1-2 years and enhanced monitoring will be required where the collaborator considered higher-risk.
Monitoring by the Foreign Interference and Transparency Committee.
Approval Authority (approves all new policies and major amendments to reviewed policies)
Vice-Chancellor and President
Governing Authority (endorses new policies and major amendments to reviewed policies; approves minor amendments to policy; approves procedures)
Deputy Vice-Chancellor (Research and Enterprise)
Responsible Officer (oversees the development and review of policies and procedures; approves minor amendments to procedures; approves editorial amendments to policies and procedures)
Pro Vice-Chancellor (Research)