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Anti Corruption and Fraud Prevention Policy

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Section 1 - Purpose / Objectives

(1) Victoria University is required to comply with certain legislation that deals with fraud and corruption control. In addition, the prevention of fraud and corruption is an essential element of the University's management and corporate governance framework.

(2) This policy establishes a framework which:

  1. Provides clear definitions of what behaviour is considered fraud and corrupt conduct and is therefore not acceptable
  2. Reinforces that fraud and corrupt conduct will not be tolerated
  3. Encourages the ongoing development of a culture espousing the highest ethical and professional standards.

(3) This policy encourages all staff to be vigilant in ensuring those standards are met and provides the authority for action if it is suspected that those standards are being breached.

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Section 2 - Scope / Application

(4) This Policy applies across the University, to all people who are part of the University community, including:

  1. Staff
  2. Students
  3. Consultants and contractors
  4. Council members
  5. Honorary, visiting and adjunct fellows
  6. Research associates
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Section 3 - Definitions

(5) Fraud:

  1. Dishonest activity causing actual or potential financial loss to any person or entity including theft of moneys or other property by employees or persons external to the entity and where deception is used at the time, immediately before or immediately following the activity.
  2. 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. (Australian Standard for fraud and corruption control).

(6) Corrupt Conduct:

  1. Conduct of any person (whether or not an employee) that adversely affects the honest performance of an employee or the University's functions;
  2. The performance of an employee's duties in a dishonest manner or with inappropriate partiality
  3. Conduct of an employee or former employee that amounts to a breach of public trust
  4. Conduct by an employee or former employee that amounts to the misuse of information or material acquired in the course of the performance of their official functions; or
  5. A conspiracy or attempt to engage in the above conduct.

(7) Improper conduct: Conduct that is corrupt, a substantial mismanagement of public resources, or conduct involving substantial risk to public health or safety or to the environment. The conduct must be serious enough to constitute, if proved, a criminal offence or reasonable grounds for dismissal.

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Section 4 - Policy Statement

Part A - Principles

(8) Victoria University will not tolerate fraud and corrupt. The University recognises the values and importance of its employees in enhancing its practices. All employees have a strong obligation to support the University's efforts in the prevention of corruption and fraud.

(9) The University will:

  1. Ensure that employees and management are aware of their responsibilities for identifying corrupt or fraudulent activities and establishing controls and procedures for preventing such activities and/or detecting such activities when they occur
  2. Provide guidance to employees as to what is required when suspicion is aroused of activities that may be fraudulent or corrupt
  3. Provide a clear statement to employees that fraudulent, corrupt or improper conduct is not acceptable and will not be tolerated
  4. Build a culture that supports employees to report conduct they suspect may be fraudulent, corrupt or improper
  5. Reduce opportunities for fraudulent, corrupt or improper conduct
  6. Ensure that appropriate action is taken if fraud, corruption or improper conduct is detected
  7. Establish an effective corruption and fraud reporting system
  8. Provide clear guidance to ensure that adequate investigation standards are followed
  9. Provide safety, protection and guidance to employees in circumstances where they are/could be victimized as a result of reporting, investigating or being a witness to fraudulent activities.

(10) It is important to note that fraud does not relate solely to theft, but also includes the use of misleading, deceptive, plagiarised or forged information, credentials or qualifications for the purposes of gaining an advantage (financial or reputational). This advantage may be represented as:

  1. An appointment or promotion to a position;
  2. A significant increase in professional reputation or esteem that improves future employment prospects;
  3. The obtaining of research or grant funding; or
  4. Any other academic benefit that occurs following the use of the fraudulent information, credentials or qualification.

Part B - Identifying and Reporting Suspected Fraud or Corrupt Conduct

(11) The Procedures associated with this Policy provide direction on the mechanism for reporting and investigating allegations of fraud and corrupt conduct.

Part C - Delegations and Accountabilities

(12) The Protected Disclosures Co-Ordinator (see Protected Disclosures Policy) is delegated to:

  1. Advise on the conduct of fraud investigations
  2. Receive confidential communications that are not protected disclosures under the meaning of the Protected Disclosure Act 2012

(13) The Protected Disclosures Co-Ordinator is accountable for:

  1. Directing people wishing to make protected disclosures to the Independent Broad-based Anti-Corruption Commission
  2. Ensuring fraud investigations are properly conducted and concluded
  3. Immediately notifying the Minister for Finance and the Auditor General where a fraud involving an amount of money over $1,000 or where the amount of property involved is more than $20,000 (a requirement of the Financial Management Act 1994).
  4. Providing an annual report to the Minister for Finance and the Auditor General of fraud matters involving an amount of money under $1,000 or where the amount of property involved is less than $20,000 (a requirement of the Financial Management Act 1994)

(14) The Manager - Financial Compliance is responsible for compiling data to form the basis of the annual report to the Minister for Finance and the Auditor General and providing this in a timely fashion to the Protected Disclosures Co-ordinator.

(15) The Manager, Risk Management and Internal Audit is responsible for conducting regular independent reviews to assess the adequacy of strategic and operational risk controls and the extent of compliance with those controls.

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Section 5 - Procedures

(16) Anti-corruption and Fraud Prevention Procedures (Pending)

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Section 6 - Guidelines

(17) Nil

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Section 7 - References

(18) Gifts, Benefits and Hospitality Policy

(19) Financial Code of Conduct Policy

(20) Staff Code of Conduct

(21) Risk Management Policy

(22) Purchasing (Credit) Cards Policy

(23) Academic Integrity and Preventing Plagiarism Policy

(24) Student Misconduct Regulations

(25) Research Misconduct Policy

(26) Protected Disclosures Policy