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Fraud and Corruption Prevention Policy

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Section 1 - Purpose

(1) To protect the University’s assets and reputation from fraudulent and corrupt activities by:

  1. reinforcing management’s commitment to, and responsibility for, identifying risk exposures to fraudulent and corrupt activities;
  2. requiring staff and others to act with honesty and integrity;
  3. establishing controls, policies and procedures to prevent and detect fraudulent and corrupt activities;
  4. encouraging the reporting of any fraud or corrupt conduct; and
  5. ensuring that all suspected corruption or fraud is dealt with appropriately.

Background

(2) Macquarie University has a broad range of stakeholders who expect the University to act in an accountable manner. If fraud or corruption is committed against the University, the impact on the University may be significant, including damage to the University’s reputation, image and standing in the community.

(3) Effective fraud and corruption control requires the commitment and involvement of all staff, students, contractors, customers, subsidiaries and external service providers. The University wants to increase awareness of what is at risk and eliminate the types of fraud and corrupt behaviour that can occur.

(4) Any fraud or corrupt act committed against the University is a major concern to the University. Consequently, any case will be thoroughly investigated and appropriate disciplinary action will be taken against the person who is found guilty of corrupt conduct. This may include referral to the Police or to the Independent Commission Against Corruption.

Scope

(5) This Policy applies to all staff, students, customers, contractors, external service providers and Controlled Entities of Macquarie University.

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Section 2 - Policy

(6) Macquarie University is committed to protecting its reputation, and its revenue, expenditure and assets from any attempt to gain illegal financial or other benefit, and will not tolerate any act of fraudulent or corrupt conduct.

(7) All staff are required to:

  1. perform their duties with honesty and integrity in accordance with the Staff Code of Conduct and Macquarie University Ethics Statement; and
  2. safeguard the resources for which they are responsible, including revenue, expenditure and assets.

(8) The University will:

  1. communicate its policy on fraud and corruption;
  2. provide fraud and corruption awareness and education so that staff know how to respond if fraud is suspected or detected;
  3. implement and operate internal controls to prevent / reduce the occurrence of fraud and corruption;
  4. investigate suspected fraud or corruption and take appropriate disciplinary action, which may include referral to the Police, against any staff member found guilty of corrupt conduct;
  5. report suspected corruption, whether or not it involves a staff member of the University, to the Independent Commission Against Corruption;
  6. in the absence of criminal prosecution, apply appropriate civil, administrative or disciplinary penalties against individuals who have been party to fraud or corruption;
  7. take any necessary legal action to recover losses that result from fraudulent or corrupt conduct;
  8. integrate fraud risk management into its philosophy, practices and business plans;
  9. create an annual Strategic Audit Plan to outline audit, risk management and risk assessment, activities for the following year; and
  10. review for effectiveness the results of risk assessments and resulting strategies.

Compliance and Breaches

(9) The University may commence applicable disciplinary procedures if a person to whom this Policy applies breaches this Policy (or any of its related procedures).

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Section 3 - Procedures

(10) Refer to the Fraud and Corruption Prevention Procedure.

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Section 4 - Guidelines

(11) Refer to the Fraud and Corruption Prevention Guideline.

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Section 5 - Definitions

(12) Commonly defined terms are located in the University Glossary. The following definitions apply for the purposes of this Policy.

(13) The University uses the definitions stated in the Australian Standard on Fraud and Corruption Control AS8001-2003 which are:

  1. Fraud: 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 whether or not 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.
  2. Corruption: dishonest activity in which a director, executive, manager, employee or contractor of an entity acts contrary to the interests of the entity and abuses his / her position of trust in order to achieve some personal gain or advantage for him or herself or for another person or entity.
  3. Investigation: a search or collation of evidence connecting or tending to connect a person (either a natural person or a body corporate) with conduct that infringes the criminal law or the policies and standards set by the affected entity.