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Office of Internal Audit & Risk Management

 

 

Anti-Fraud Policy

Index

Introduction
Policy
Guidelines
Administrative Procedures

INTRODUCTION

Fraud and Corruption prevention is about changing organisational features that allow these events  to occur and possibly go unnoticed or unreported. Strategies incorporated in the fraud  prevention plans should address issues such as accountability, efficiency and effective administration. They should focus on improving systems and procedures, changing the attitudes of staff and improving the overall integrity and performance of the University. This could be incorporated in one unwieldy document or as we are attempting here, to incorporate it in several - such as the Codes of Ethics and Conduct, Code of Conduct for Research, the Policies and Procedures Manuals etc.

This policy covers the prevention, detection and management of fraud and for fair dealing in matters pertaining to fraud.

It aims to raise the awareness of fraud and its prevention in the University environment and to give guidance to both the reporting of suspected fraud and how the investigation of that report will proceed.

The eight policy objectives cover:

  • Management awareness of anti-fraud responsibilities
  • Employee guidance if fraud is suspected
  • A statement forbidding misconduct
  • Investigation responsibilities
  • Assurance that fraud will be fully investigated
  • Protection guidelines for those reporting suspected fraud
  • Involvement of the Anti-Corruption Commission
  • Development of a suitable environment for fraud management.

Whilst this policy does not enumerate the steps required to prevent fraud it revisits the ongoing responsibilities for the controls designed to prevent fraud. The controls are discussed further under  Section 2.2 - Responsibilities for Implementation of this policy.

Divisions, Schools and Offices (DSO) are required to create an environment that discourages fraud. This is discussed at Section 2.3 - Environment and Culture.

The Office of Human Resources have responsibilities under other sections. Firstly under Section 2.4 - Recruitment of Staff, secondly under Section 2.5 - Staff Development and Training and finally, under Section 3.4.1  - Awareness of the Anti-Corruption Commission Act.

1.    POLICY

1.1   Policy Statement

The University has measures for the prevention, detection and management of fraud and for fair dealing in matters pertaining to fraud.

1.2   Policy Objectives

  • To ensure that management is aware of its responsibilities for identifying exposures to fraudulent activities and for establishing controls and procedures for preventing such fraudulent activity and/or detecting such fraudulent activity when it occurs.
  • To provide guidance to employees as to action which should be taken where they suspect any fraudulent activity.
  • To provide a clear statement to staff forbidding any illegal activity, including fraud for the benefit of the University.
  • To provide clear guidance as to responsibilities for conducting investigations into fraudulent activities.
  • To provide assurances that any and all suspected fraudulent activity will be fully investigated.
  • To provide adequate protection and guidance as to appropriate action to employees in circumstances where they are victimised as a consequence of reporting, investigating or being a witness to, fraudulent activities.
  • To ensure that the requirements of the Anti-Corruption Commission Act (WA)1988 ("the Act") are met and that all University employees are advised of their rights and responsibilities under the Act.
  • To provide a suitable environment for employees to report matters that they suspect may concern corrupt conduct, criminal conduct, criminal involvement or serious improper conduct.

1.3   Definitions

Fraud is not restricted to monetary or material benefits. It includes intangibles such as status and information. For the purpose of this policy, fraud against the University is described as:

"Inducing a course of action by deceit or other dishonest conduct, involving acts or omissions or the making of false statements, orally or in writing, with the object of obtaining money or other benefits from or of evading a liability to, the University."

Definitions associated with the Anti-Corruption Commission Act (WA) 1988 are contained in the Administrative Procedures section.

1.4   Strategies

The associated policies and industrial agreements at Murdoch University for the prevention, detection, management and reporting of fraud and corrupt conduct have several elements, including;

2.    GUIDELINES

2.1    Responsible Officers

The Anti-Fraud Management group is responsible for the control and administration of the University’s Anti-Fraud policy. This group shall be selected from within the University and include:

  • Deputy Vice-Chancellor;
  • Director, Human Resources; and
  • Director, Internal Audit and Risk Management.

In addition the group shall be empowered to co-opt the services of other persons as appropriate.

The Deputy Vice-Chancellor shall promulgate and update the Anti-Fraud Policy.

2.2    Responsibilities for Implementation of This Policy

The Vice-Chancellor accepts ultimate responsibility for the prevention and detection of fraud and is responsible for ensuring that appropriate and effective internal control systems are in place.

The Internal Audit  function supports the Vice-Chancellor in ensuring appropriate and effective internal control systems are operating.

All  managers must share responsibility for the prevention and detection of fraud and for the carriage of the Murdoch University Fraud Strategy. Similarly, all staff must share in that responsibility.

It is the responsibility of all managers to ensure that there are mechanisms in place within their area of control to:

  • assess the risk of fraud;
  • promote employee awareness of ethical principles subscribed to by the University; and
  • educate employees about fraud prevention and detection.

For this purpose, managers will be supported by relevant services within the University.

Although activities may be undertaken by others, it is each manager’s responsibility to actively support and encourage those activities and to be sure that they extend to his or her area of organisational responsibility. For this purpose they should incorporate into their annual planning processes, fraud control plans covering risk assessment, awareness programs and training.

All employees have the responsibility to report suspected fraud.  Fraud constitutes a form of corrupt conduct and reference should be made to the administrative procedures relative to the Anti-Corruption Commission Act  (WA) 1988. Any employee who suspects fraudulent activity must immediately notify their supervisor or a member of the Anti-Fraud Management group.

DSO should ensure that they:

  • Display a positive, appropriate attitude towards compliance with laws, rules and regulations;
  • Are aware of common indicators/symptoms of fraudulent or other wrongful acts (e.g. by participation in relevant staff training programs and/or literature research) and respond to those indicators as appropriate;
  • Establish and maintain proper internal controls to provide for the security and accountability of University resources and prevent / reduce the opportunity for fraud.  Details of common areas of fraud and indicators of fraud are described in the document:  Fraud Prevention in the Western Australian Public Sector, Ministry of Premier and Cabinet, 1999.  The document can be downloaded from http://www.mpc.wa.gov.au/psmd/pubs/psrd/governance/fraud.html.
  • Are aware of the risks and exposures inherent in their area of responsibility.
  • Respond to all allegations or indications of fraudulent or wrongful acts.

The operation of internal controls is not the responsibility of the Office of Internal Audit and Risk Management.  Financial internal controls, administrative internal controls and academic systems internal Controls are all requirements for fraud prevention.  Responsibility for controls can be blurred. In such cases,  Executives need to clearly identify, through normal channels of authority, where responsibility lies. Ultimately, responsibility for Internal Control rests with the Vice-Chancellor  (Financial Administration and Audit Act (WA) 1985 ). Consistent with the Auditor General’s guidelines, line managers are responsible for daily operations and for the internal control systems within their organisational responsibility.  Where managers do not have the expertise to evaluate internal control they may wish to call on support from Internal Audit or from other central services.

The provisions of this policy do not deny an individual from taking action under the terms of the industrial provisions prevailing at the time.

The policy is to provide for strategies aimed at preventing, detecting and dealing fairly with matters pertaining to fraud that integrate the activity of management and staff at all levels across the diversity of operations and activities at Murdoch University.

2.3    Environment and Culture

DSO must create an environment and culture in which employees believe that dishonest acts will be detected and investigated. To this end, they must:

  • participate in in-house training programs covering fraud, fraud detection and fraud prevention;
  • ensure staff understand that the internal controls are designed and intended to prevent and detect fraud;
  • encourage staff to report suspected fraud directly to those responsible for investigation without fear of disclosure or retribution; and
  • require vendors and contractors to agree in writing as a part of the contract process, to abide by the Murdoch University policies and procedures, and thereby avoid any conflict of interest.

Measures to prevent fraud should be continually monitored, reviewed and developed particularly as new systems, programs, contracting or arrangements are introduced or modified.

All complaints of suspected fraudulent behaviour will be thoroughly and carefully investigated as specified in Section 3.3 - Administrative Procedures, whilst also providing for the protection of those individuals making the complaint and natural justice to those individuals being the subject of such complaint.

2.4    Recruitment of Staff

Recruitment policy and practices underpins fraud prevention. DSO in particular, must support the human resource recruitment strategies aimed at fraud prevention, these include:

  • criminal background checks on employees, where the position warrants it;
  • contacting previous employers and referees, and
  • verifying transcripts, qualifications, publications and other certification or documentation.

2.5    Staff Development and Training

Courses / seminars on the topic of fraud, fraud detection and fraud prevention will be developed by Human Resources, with assistance from Internal Audit, as necessary.

Fraud prevention and detection issues will be included in other relevant staff development and induction activities.

Human Resources will put suitable induction and awareness procedures relative to the Act in place.

2.6    Resources

There are no large additional resource requirements envisaged as a consequence of the adoption of this policy.

2.7    Authority for Approving Amendments to the Anti-Fraud Policy

The Vice-Chancellor is responsible for approval of this Policy.  The Audit Committee shall be advised of any changes to the policy.

2.8    Effective Date

The Anti-Fraud Policy shall come into effect immediately upon approval by the Vice-Chancellor.

2.9    Review of Policy

In the interests of maintaining best practice, the policy on Anti-Fraud shall be reviewed by the Director, Internal Audit and Risk Management every two years, or sooner where there is an amendment to the legislation and/or Guidelines provided by the Commission. The outcome of the review shall be reported to the Vice-Chancellor through the Audit and Risk Management Committee.

3.     ADMINISTRATIVE PROCEDURES

3.1    Definitions

"Commission" means Anti-Corruption Commission established under Section 5 of the Act.

"corrupt conduct" means where a public officer has -

  • corruptly acted or corruptly failed to act in the performance of functions of his or her office or employment; or
  • corruptly taken advantage of his or her office or employment as a public officer to obtain any benefit for himself or herself or for another person.

"criminal conduct" means where a public officer has -

  • committed a scheduled offence whilst acting or purporting to act in his or her official capacity; or
  • committed an offence under section 552 of The Criminal Code by attempting, whilst acting or purporting to act in his or her official capacity, to commit a scheduled offence; or
  • committed an offence under section 553 of The Criminal Code by attempting, whilst acting or purporting to act in his or her official capacity, to commit a scheduled offence; or
  • committed an offence under section 558 of The Criminal Code by attempting, whilst acting or purporting to act in his or her official capacity, to commit a scheduled offence.

"criminal involvement" means where -

  • another person has been involved in criminal conduct engaged in by a public officer in such a manner that the other person could be regarded, under Chapter II of The Criminal Code, as having taken part in committing an offence, or as having committed an offence or as having been an accessory after the fact to an offence.

 "public officer" has the same meaning as in The Criminal Code.

"serious improper conduct" means where a public officer has engaged in conduct (other than corrupt conduct or criminal conduct that –

  • adversely affects, or could adversely affect, directly or indirectly, the honest or impartial performance of the functions of a public body or public officer; or
  • constitutes or involves the performance of the public officer’s functions in a manner that is not honest or is not impartial; or
  • constitutes or involves a breach of the trust placed in the public officer by reason of his or her office or employment as a public officer; or
  • involves the misuse of information or material that the public officer has acquired in connection with his or her functions as a public officer, whether the misuse is for the benefit of the public officer or another person, and constitutes or could constitute -
  • an offence against the Statutory Corporations (Liability of Directors) Act 1996 or any other written law; or
  • a disciplinary breach providing reasonable grounds for the termination of a person’s office or employment as a public service officer under the Public Sector Management Act 1994 (whether or not the public officer to whom the allegation relates is a public service officer or is a person whose office or employment could be terminated on the grounds of such conduct).

It could for example, include breach of public trust, neglect of duty, function or power, telling lies, favouritism, bias and breach of public sector standards. No list can be exhaustive.

3.2    Responsibilities

Section 55 of the Financial Administration and Audit Act (WA) 1985 places responsibility on the Senate, as the accountable authority, for, amongst other things:

  • control over expenditure ensuring that such expenditure is in accordance with legal requirements;
  • the custody, control, management and accounting of all public property and other property of or under the control of the University; and
  • the development and maintenance of an effective system of internal control and an effective internal audit function.

3.3    Investigations of Complaints

If a complaint is received by the employee’s supervisor a written summary should be requested from the complainant. Where the complainant does not wish to provide a written summary the supervisor should take detailed written notes of the meeting. Supervisors are required to maintain confidentiality with respect to complaints or  matters referred to them.

Allegations of misconduct or fraud made by staff or students about other staff or students would generally be covered by the legal protection of 'qualified privilege', provided that the allegations are made

  • honestly and without any improper motive; and
  • to a person with a legitimate interest or duty in the subject matter.

Qualified privilege will not apply if the allegations are communicated to persons without such interest or duty.

Any statements, reports or letters containing potentially defamatory statements should be clearly marked 'Private and Confidential' to the addressee.

Great care needs to be taken in the investigation of suspected improprieties or irregularities, which fall within the definitions of the Policy and these Administrative Procedures, so as to avoid incorrect accusations or alerting individuals against whom an allegation has been made that a matter has been raised and an investigation is underway, and also to avoid making statements which could expose the maker to legal liability. Accordingly, the complainant or supervisor should not:

  • attempt to personally conduct investigations or interviews in order to determine whether or not a suspected activity is improper;
  • contact the suspected individual(s) to determine facts or demand restitution; or
  • discuss any facts, suspicions or allegations associated with the case with anyone, unless specifically directed by a member of the Anti-Fraud Management group, the law enforcement or regulatory agencies.

The supervisor should report the matter(s) to the Anti-Fraud Management group within one working day of their acquiring knowledge of the matter(s), or in cases where this is not practicable, as soon as is possible.

The Anti-Fraud Management group will initially conduct a preliminary fact finding review.

Confidentiality concerning the complainant and the information will be maintained at all stages.

After the preliminary review of the complaint / matter / suggestion the Anti-Fraud Management group may request assistance from DSO for independent evidence as to the validity of the complaint, advice as to possible causes and corrective action.

When an audit reveals an allegation of corrupt or criminal conduct, criminal involvement or serious improper conduct, the Anti-Fraud Management group shall be notified immediately by the Office of Internal Audit. Assistance may be sought from other areas, as necessary.

When allegations of corrupt or criminal conduct, criminal involvement or serious improper conduct are received by the Security section of the Office of Facilities Management such matters must be referred by them to the Anti-Fraud Management group

In order to avoid damaging the reputations of innocent persons initially suspected of wrongful conduct, and to protect the University from potential civil liability, the results of the audits/investigations will be disclosed or discussed only with those persons who require the knowledge in the proper performance of their office or function.

Appropriate personnel action shall be initiated by the Director, Human Resources. This action may cover suspension with pay while the matter is being investigated through to the termination of any staff member involved in the fraud.  Advice will need to be sought from the Employee Relations Officer.

Where appropriate the staff member involved in the fraud shall be given twenty four hours to respond in writing to the written request for information concerning the suspected fraud.

The Anti-Fraud Management group will ensure that appropriate documentation of the facts has been achieved in order to permit :

  • appropriate personnel action;
  • protection of innocent persons;
  • support appropriate civil or criminal actions;
  • documentation of claims against the University’s insurers;
  • preservation of the integrity of any criminal investigation and prosecution; and
  • avoidance of any unnecessary litigation.

Everybody must co-operate fully with law enforcement and regulatory agencies (e.g. Anti-Corruption Commission and W A. Police Service), including reporting to such agencies and support of prosecution, where necessary.

3.4    Anti-Corruption Commission Act

3.4.1    Awareness

At the commencement of each semester an appropriate notice shall be placed on the Web at the HR Home Page under News Desk by Human Resources as a reminder to employees that they may report such matters to the Commission.  This notice will  refer to a page on the Murdoch University web home site at which will be located:

  • up to date references to relevant sections of the Act, and
  • action which shall or may be taken when matters falling within the ambit of the Act come under notice,

Web site link:  http://wwwadmin.murdoch.edu.au/hr/

The Human Resources induction package for new employees shall include a notice referring to requirements under the Act.

3.4.2    Compulsory Reporting Under Section 14 of the Anti-Corruption Commission Act 1988

Section 14 of the Act provides that the principal officer of the University (the Vice-Chancellor) shall report to the Commission any matter -

  • which that person suspects on reasonable grounds concerns or may concern corrupt conduct, criminal conduct, criminal involvement or serious improper conduct; and
  • which is of concern to that person in his or her official capacity.

Reports required under Section 14 of the Act should be copied in confidence to the Chair of the Audit Committee, the Chancellor and the Senate.

If there is a doubt in the mind of anyone as to whether he or she has a duty to report to the Commission, then that person should immediately communicate with the Anti-Fraud Management group in the first instance.  The Anti Corruption Commission's Chief Executive Officer or  Registrar can be consulted as as necessary to clarify the matter. The W A Police Public Service Investigation Unit can also be used as a sounding board if required.  

Complaints or reports by current employees about corrupt or criminal conduct, criminal involvement or serious improper conduct should generally be made to the complainant’s immediate supervisor, who should in turn report the issue through the chain of command to the Deputy Vice-Chancellor.

If the complainant does not want to involve his/her supervisor, an alternative channel for confidential reporting is available by direct reporting to any member of the Anti-Fraud Management group.

Where the employee does not wish to report the matter to their supervisor or to the Anti-Fraud Management group, the matter may be reported directly to the Vice-Chancellor.  Employees are encouraged not to report directly to the Vice-Chancellor where the Anti-Fraud Management group is available.

Where the employee does not wish to report the matter to their immediate supervisor, the Anti-Fraud Management group or the Vice-Chancellor, a complaint of corrupt or criminal conduct, criminal involvement or serious improper conduct may be made direct to the Commission under Section 16 of the Act.

Supervisors must maintain confidentiality and report matters related to corrupt or criminal conduct, criminal involvement or serious improper conduct to the Anti-Fraud Management group within one working day of their acquiring knowledge of the matters or, in cases where this is not practicable, as soon as is possible.

The Anti-Fraud Management group shall provide the Vice-Chancellor with a report on matters of corruption referred to Anti-Fraud Management group as soon as practicable and recommending proposed action.

Matters considered for referral to the Commission by the Vice-Chancellor under Section 14 of the Act should, in the first instance, be referred (preferably in writing) to the Anti-Fraud Management group for advice and initial investigation.

Complainants are encouraged to provide a written summary of any complaint.  If the complainant is unwilling to do so, supervisors are required to make complete written notes of the complaint.

Employees are encouraged not to make complaints anonymously as anonymous complaints may be difficult to pursue if further information is required and they prevent reporting back to the complainant.  Well founded anonymous complaints will, however, receive due and proper consideration.

Written, signed and dated summaries by the complainant should identify, where known/possible, the:

  • section and/or location of the alleged incident;
  • key person(s) involved;
  • nature of the alleged incident;
  • time period over which the alleged incident has occurred;
  • value associated with the alleged incident; and
  • documentary evidence in support of the alleged incident.

Where a matter is considered appropriate for official reporting a draft report shall be prepared by the Anti-Fraud Management group, with an initial review being performed by the Anti-Fraud Management group. If the matter is serious or urgent, phone contact should be made with the Commission Registrar in the first instance.

The final draft of the report shall be forwarded to the Vice-Chancellor for signature, with a copy to the University Secretary  for information.

All matters should be reported to the Commission which give the Vice-Chancellor reasonable grounds to suspect that a public officer has engaged in official corruption or other criminal conduct as set out in section 13 (1) (a) - (c) of the Act and which is of concern to the Vice-Chancellor in his/her official duties. This requirement for reporting is in addition to the usual duties of office and it should not inhibit any action that should be taken by the Vice-Chancellor as part of his or her normal official responsibilities in dealing directly with such matters. All such action taken, or intended, is to be included in the report to the Commission.

Reports should be made in writing and forwarded to the Chief Executive Officer, Anti- Corruption Commission. They may be brief in the first instance but should contain a description of the particular wrongful act suspected and of the evidence which might substantiate it as well as associated issues and of the action which has been taken or which is intended in relation to it. Such action may include referral to other bodies. The Anti-Corruption Commission will forward a pro-forma to the Director, Internal Audit for completion prior to official notification by the Vice-Chancellor.    The Vice-Chancellor is the official reporting authority representative of the University for contact with the Commission.  The name and telephone number of that officer should be added to the report to the Commission for the purpose of communications.

A confidential means of transmission to the Commission is to be used, and all documents relating to this shall be treated at all times in a confidential manner.

The Commission is to be kept informed by the Vice-Chancellor of significant developments as they occur.

Complainants, unless anonymous, will generally be advised of the eventual outcome of cases and will, to the extent permitted by the Commission, be kept informed throughout the process of an investigation, via the Anti-Fraud Management group.

Where the complainant is an employee, the employee will be advised confidentially by the Vice-Chancellor when a matter has been referred to the Commission.

Where the complainant is not a current employee, they will not be advised of referral to the Commission until the Commission reports back to the Vice-Chancellor.

For register purposes, a summary of reports made to the Commission in the annual period to 31 May each year is to be forwarded by 30 June each year by the responsible authority under Section 14. A nil return is required if no reports have been made. That report shall be drafted by the Anti-Fraud Management group, and shall be signed by the Vice-Chancellor.

3.4.3    Voluntary Reporting Under Section 16 of the Anti-Corruption Commission Act 1988

Section 16 of the Act provides that a person (including a public officer) may report to the Commission any matter which that person suspects, on reasonable grounds, concerns or may concern corrupt conduct, criminal conduct, criminal involvement or serious improper conduct.

Employees should be encouraged, in the first instance, to refer their suspicions to the Anti-Fraud Management group for advice and the conduct of an initial review, prior to any reporting to the Commission under either Section 16 (by the employee ), or under Section 14 ( by the Vice-Chancellor as the principal officer of the University ). Such references shall be treated as strictly confidential.

Where the employee does not wish to report the matter to their immediate supervisor, the Anti-Fraud Management group or the Vice-Chancellor, then the previous paragraph does not in any way restrict an individual's ability, as they see fit, to make a complaint of corrupt or criminal conduct, criminal involvement or serious improper conduct directly to the Commission under Section 16 of the Act.

If there is a reasonable doubt about the duty to report to the Commission, then the person reporting should immediately communicate with the Anti-Fraud Management group in the first instance and with the Commission Registrar, as necessary, for clarification.

3.4.4    Confidentiality

Any report or information passed to the Commission is to be kept confidential and the fact that the Commission has received such report or information, or any details, should be conveyed only to those people who require the knowledge in the proper performance of their office or function. In this regard, attention is drawn to Section 54 of the Act dealing with restriction on publication of certain information or allegations.

Confidentiality will be maintained. Any reports back to the complainant will be made in a manner so as not to compromise that confidentiality.

Any breaches of confidentiality may be brought as a grievance under the University's Discrimination and Harassment Grievance Policy, or alternatively via existing remedies at law.

3.4.5    Action on Complaints

When acting pursuant to section  3.4.2.,  the Anti-Fraud Management group shall carry out such investigation as the Vice-Chancellor approves or directs and shall do so with all the rights and powers normally available under the Financial Administration and Audit Act, 1985, Treasurer’s Instructions and the Internal Audit Charter.

Unless otherwise directed by the Vice-Chancellor, the Anti-Fraud Management group is responsible for co-ordinating investigations into matters of corrupt or criminal conduct, criminal involvement or serious improper conduct.

The Vice-Chancellor shall be responsible for ensuring that controls are reviewed and updated. The Director, Internal Audit  and Risk Management shall act for the Vice-Chancellor with respect to the review. DSO are responsible for the with daily involvement in implementing controls. 

The Vice-Chancellor shall be responsible for taking appropriate action against any employee(s) involved in matters of corrupt or criminal conduct, criminal involvement or serious improper conduct in accordance with the provisions of industrial awards/agreements prevailing at the time.

3.4.6    Contact With The Anti-Corruption Commission

Any questions about the function of the Anti-Corruption Commission, the required reports or any other matters relating to official corruption may be directed to the Registrar of the Commission either in writing or by telephone. An alternative contact is the Commission Registrar.  Questions may also be directed to the WA Police Public Services Investigations Unit.

3.4.7    Prevention of Victimisation

Section 53 of the Anti-Corruption Commission Act states that:

A person shall not -

  • prejudice, or threaten to prejudice, the safety or career of; or
  • intimidate or harass, or threaten to intimidate or harass; or
  • do any act that is, or is likely to be, to the detriment of, another person because the other person -
  • has assisted, is assisting or will or may in the future assist the Commission in the performance of its functions; or
  • has furnished, is furnishing or will or may in the future furnish information to the Commission; or
  • has been or is, or has been or is employed by or acting on behalf of, an independent agency or appropriate authority to whom or which an allegation has been referred under section 22(1); or
  • has exercised a power, or performed a duty, conferred or imposed by this Act on the other person or is exercising or performing, or will or may in the future exercise or perform, any such power or duty."
  • Penalties are defined in the Act.

Employees must be assured that they will not be victimised or disadvantaged by making a complaint, and that the Act prescribes penalties for such actions. Employees should be assured that the Act has provisions, supported by University procedures, which ensures that they will not be victimised or disadvantaged by making a complaint. Action to cover up the wrongdoing and or to retaliate against, or victimise witnesses is strictly forbidden, and could itself constitute conduct within the jurisdiction of the Commission.

Any person who considers that they are being victimised as a consequence of the assistance being provided to the Commission, should in the first instance contact the Director, Human Resources or nominee for guidance as to appropriate steps which may be taken to alleviate the situation.

All suspects will be treated consistently without regard to position held, past performance or length of service, together with due regard to natural justice and procedural fairness. Where malicious accusations and or procedural unfairness is perceived to have occurred, the chance to be heard is available through procedures associated with the University Discrimination and Harassment Grievance Policy.

4.    Authority for Approving Amendments to the Administrative Procedures

The Audit Committee is the authority for approving amendments to the administrative procedures of the University’s policy on Anti-Fraud.

Approved

 

Vice-Chancellor

Date:

 

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