(1) This Guideline states the University’s strategy for the prevention of Fraud and Corruption. (2) Guidance is provided on the following topics: (3) Refer to the Fraud and Corruption Prevention Policy. (4) Reefer to the Fraud and Corruption Prevention Procedure. (5) The risk of fraud and corruption is ever present. The following are some of the factors that add to, or at least change, the University’s risk: (6) Fraud and corruption prevention strategies demonstrate sound management practice and governance and assist the University in deterring unethical behaviour. (7) The outcomes of committing fraud can be either tangible or intangible and can involve misuse of: (8) It is possible for anyone to commit fraud or corruption. It can be done alone or in collusion with others within or outside the University. Fraud or corruption could be perpetrated against the University by: (9) You need to be kept informed about the University’s Fraud and Corruption Prevention and Response Strategy and what part you are expected to play in it. The University will achieve this in a number of ways, including: (10) The early detection of fraud and corruption is an essential element of the University’s prevention strategy. (11) Surveys of fraud conducted in Australia regularly demonstrate that employees are the most likely to discover fraud. As a member of staff, you are therefore the key factor in detecting fraudulent or corrupt behaviour. (12) It should be your aim to detect fraud or corruption as soon as possible after it occurs. There are a number of ways in which fraud may be detected. These may include: (13) The University is covered by Industrial Special Risks insurance. The insurance is renewed on an annual basis (currently 31 October each year). This insurance covers physical loss, destruction or damage to all real and personal property of every kind and description belonging to the University or for which the University is responsible or has assumed responsibility to insure prior to the loss. There are no geographical limits on this cover. (14) The two components relevant to this strategy include: (15) There is currently an excess on each claim. (16) The policy covers any person acting as an agent of the University in carrying out their duties at the University. (17) The Industrial Special Risks insurance policy is maintained by the Office of Financial Services. (18) A Strategic Audit Plan is prepared each year by an external audit firm and signed off by the Audit and Risk Committee. This Plan outlines audit and risk management activities for the ensuing year. (19) The Strategic Audit Plan also incorporates a University-wide risk assessment that provides the basis for refining the scope and objectives of each of the audit and risk management activities to be undertaken. (20) An Internal Audit Plan is prepared by Deloittes and plays a crucial role in the prevention of fraud and corruption within the University. (21) The University outsources its Internal Audit on a three-year cycle. The Internal Audit function is conducted by Deloittes, which reports to the University’s Audit and Risk Committee. (22) In relation to fraud and corruption control, the University’s internal audit includes ongoing reviews of controls within the University, including: (23) The Fraud and Corruption Prevention and Response Strategy is a best practice of the Independent Commission Against Corruption (ICAC). It is a framework for how the University prevents and responds to fraud. (24) Fraud and corruption control requires continuous discussion. This may include: (25) The fraud and corruption control and response strategy is prepared, reviewed and amended as required by the Fraud Control Officer. (26) The University aims to conduct fraud risk assessments at least every three (3) years. Where appropriate, the University may introduce a rolling program of risk assessments. (27) When the University undergoes a substantial change in structure or function, or where there is a significant transfer in function (for example, as a result of outsourcing), the University may undertake further fraud risk assessment in relation to the changed functions. This fraud risk assessment may form part of a general business risk assessment exercise. (28) Staff at all levels in the University should be involved in the fraud and corruption risk assessment process, particularly those with detailed knowledge of the University’s practices and procedures, because they understand system weaknesses and whether internal controls are being adhered to. The University recognises that it is important to ensure that the staff involved have relevant training, access to all necessary information and an understanding of the areas to be examined. (29) The University’s risk assessment must consider fraud risks from both within the University and from external factors. Risk assessments must also consider fraud risks that may emerge in the future. For example, the University needs to be aware of the changing nature of fraud arising from the greater use of external service providers and developments in information technology. (30) Core areas that a fraud risk assessment should consider include: (31) Fraud and corruption risk assessments should be conducted in accordance with the Australian/New Zealand Standard (AS/NZS 4360:1999) - Risk Management. The University documents the risk assessment process in order to: (32) Fraud risk assessments provide details of the University’s risk profile and vulnerability. Unauthorised access could substantially undermine the viability and effective management of the University. Therefore fraud risk assessments may be restricted in circulation, consistent with the sensitivity of the material or subject matter. (33) It is important that fraud and corruption risks are considered in the broader context of overall business risk so that fraud risk assessment takes into account University-wide strategic planning. Fraud risk should not be looked at in isolation from the general business of the University. There is considerable overlap between enterprise risk, business risk, audit risk, security risk and fraud risk. Other risk management approaches may have already highlighted changes in strategic directions that will impact on future fraud risk profiles and control frameworks. (34) All fraud and corruption risks rated as having a High or Very High level of residual seriousness require one or more proposed actions aimed at achieving one or more of the following: (35) The University may also develop proposed actions for risks assessed as being a lower residual risk. To ensure comprehensive implementation and provide a periodic check on progress, the risk assessment teams should, where possible, allocate personal responsibility for the implementation of each action item. (36) It is expected that Faculties and Offices will review the results of the fraud risk assessments at least annually to ensure that strategies developed during the course of the most recent fraud risk assessment are reviewed for effectiveness and amended where necessary. (37) The Fraud Control Officer coordinates the compliance with the annual review of fraud mitigation strategies. (38) Commonly defined terms are located in the University Glossary. The following definitions apply for the purpose of this Guideline: (39) The Australian Standard on Fraud and Corruption Control AS8001-2003 defines corruption as: (40) The Independent Commission Against Corruption (ICAC) defines corrupt conduct, as it affects a public authority, as: (41) Examples of corrupt conduct to which the University may be subject include: (42) Fraud is recognised as a subset of corruption. (43) The Australian Standard on Fraud and Corruption Control AS8001-2003 defines fraud as: (44) Examples of fraud on the University include, but are not limited to:Fraud and Corruption Prevention Guideline
Section 1 - Purpose
Top of Page
Section 2 - Policy
Section 3 - Procedure
Section 4 - Guideline
Assets of the University Vulnerable to Fraud and Corruption
Perpetrators of Fraud and Corruption
Fraud and Corruption Awareness
Fraud and Corruptions Detection
Fidelity Guarantee Insurance
Fraud and Corruption Risk Management
Strategic Audit Plan
Internal Audit Plan
Fraud and Corruption Prevention and Response Strategy
Risk Assessment
Integrating Fraud and Corruption Risk Assessment with Overall Risk Assessment
Implementation of Proposed Actions
Review of Effectiveness of Strategies
Section 5 - Definitions
Definition of Corruption
Definition of Fraud
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