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Fraud Control Policy

Overview

The Fraud Control Policy represents the commitment of the University to effective fraud risk management. It also requires the commitment, cooperation and involvement of all staff in preventing, detecting and responding to all instances of fraud.

Scope and Application

This Policy applies to the University's teaching, learning, research, enabling and support activities. It also applies to all Controlled Entities. For the purpose of this Policy, the term "staff" refers to all employees, titleholders, consultants and contractors.

The University has adopted the following definition of fraud:

"Dishonestly obtaining or attempting to obtain a benefit or advantage for any person or dishonestly causing or attempting to cause a detriment to the University of Adelaide or its Controlled Entities"

Student fraud, including plagiarism, cheating, non-payment of fees or manipulation of grades, is governed by the Policy on Plagiarism, Policy on Cheating in Examinations and Related Forms of Assessment and the Rules for Student Conduct.

Fraud against the University is an offence under various provisions of State and Commonwealth legislation. Fraud also constitutes serious misconduct under the University of Adelaide Collective Agreement.

Policy Principles

1. The University's attitude to fraud

a) The University has a zero tolerance to fraud.

b) The University is committed to minimising the incidence of fraud through the development, implementation and regular review of fraud prevention, detection and response strategies.

2. The University's approach to fraud

a) The University will ensure that all staff are aware of the fraud reporting procedures and actively encouraged to report suspected fraud through the appropriate channels.

b) The University has adopted a clear framework and approach to fraud detection and prevention, the full details of which appear in its Fraud Control Plan. This approach is based on the Australian Standard for Fraud and Corruption Control AS 8001:2008. In particular, the following fraud control strategies may be implemented by the University:

Prevention Strategies

Detection Strategies

Integrity Framework - Code of Conduct Guidelines

Data Analysis

Fraud Control Plan (including allocation of fraud prevention responsibilities)

Management Reports reviews

Fraud Awareness Training

Fraud Awareness Training

Fraud Risk Assessments

Clear reporting channels

Robust internal controls

Whistleblower protection

Pre-employment screening

c) All information received by the University in relation to suspected fraudulent conduct will be collected, classified and handled appropriately having regard to privacy, confidentiality, legal professional privilege and the requirements of natural justice.

d) If fraud against the University is detected, the Vice Chancellor and President will make all decisions on the appropriate communications protocol by nominating one person to be the authorised spokesperson. Any communications relating to a fraud incident by a person other than the Vice Chancellor and President or authorised spokesperson will be unauthorised.

3. Expectations of University staff

a) Staff are expected to act in a professional and ethical manner, follow legal requirements, care for property, maintain and enhance the reputation of the University.

b) Staff are expected to remain vigilant to any suspected fraudulent behaviour that may be occurring around them and are expected to fully cooperate with any investigations and the implementation of fraud control strategies.

c) Staff who become aware of suspected fraudulent conduct must report the matter in accordance with this Policy.

d) Staff must retain strict confidentiality on any University fraud incidents of which they have knowledge.

e) Managers must uphold and monitor fraud control strategies within their area of responsibility.

f) Any failure by staff to comply with this Policy may result in disciplinary action against them.

4. Examples of what constitutes fraud

The following list, whilst not exhaustive, provides examples of the types of conduct that would be included within the University's definition of fraud:

a) Theft of property eg. inventory, cash and equipment.

b) Unlawful or unauthorised release of confidential information that is dishonest.

c) Dishonestly obtaining or using property that belongs to the University.

d) Dishonest use of intellectual property.

e) Causing a loss to the University that is dishonest, or avoiding or creating a liability for the University by deception.

f) Knowingly making or using forged or falsified documents that is dishonest.

g) Dishonestly using the University's computers, vehicles, telephones, credit cards, cab vouchers and other property or services.

h) Fabrication, falsification or plagiarism of research or scholarly work.

i) Dishonestly falsifying invoices for goods or services.

j) Dishonestly using purchase or order forms to gain a personal benefit.

k) Receiving or giving kickbacks or secret commissions to or from third parties.

l) Dishonestly assisting or enabling the unlawful or unauthorised transfer, use or allocation of University property and assets including moneys and/or funds held by or on trust for the University.

m) Dishonestly using grant or research funds or sponsorships.

Procedures

5. If you suspect fraud - reporting procedure

Responsibility: All staff

a) In the first instance, report any suspected fraud incident to your Head of School or Branch, or relevant line manager.

b) If, for any reason, you feel that reporting the incident through your Head of School or Branch or relevant line manager would be inappropriate, report the matter directly to the General Counsel (celine.mcinerney@adelaide.edu.au or phone (08) 8303 4539). Such reports may be made confidentially, if desired.

c) In the event of the allegation involving the General Counsel or one of the Deputy Vice-Chancellors or Vice-Presidents, refer the incident directly to the Vice Chancellor and President.

d) Any Branch Head or Head of School (or relevant line manager) receiving a report of alleged fraud must advise the relevant Executive Dean (if applicable) and immediately report the fraud to the General Counsel.

e) All staff are required to act in good faith and reasonably in reporting alleged fraudulent activity.

f) University Management must communicate non-trivial instances of suspected or actual fraud to the Chair of the Audit, Compliance and Risk Committee and to the Chancellor and they must be informed of steps taken.

A flowchart depicting the designated reporting channels and fraud incident handling process within the University is attached to this Policy.

RMO File No. 2006/4980
Policy custodian Vice-Chancellor and President
Responsible policy officer General Counsel
Approved by University Council on 13 October 2008
Procedures approved by University Council on 13 October 2008
Related Policies Code of Conduct
http://www.adelaide.edu.au/policies/2323/

Conflict of Interest Policy and Guidelines http://www.adelaide.edu.au/policies/1243/

University of Adelaide Collective Agreement http://www.adelaide.edu.au/hr/conditions/eb/

Policy on Plagiarism
http://www.adelaide.edu.au/policies/230/

Policy on Cheating in Examinations and Related Forms of Assessment http://www.adelaide.edu.au/policies/1963

Rules for Student Conduct
http://www.adelaide.edu.au/policies/33/

Effective from 13 October 2008
Review Date 30 June 2011
Contact for queries about the policy General Counsel, tel: 36080

Enclosed documents

Title Version Date uploaded
Fraud Control Policy d2008/16701 12 May 2010
Fraud Control Plan d2008/16702 11 Feb 2010
Plan - diagrammatic representation d2008/16703 1 Jul 2009
App B - Fraud Control Responsibilities d2008/16704 1 Jul 2009
App C - Fraud Risk Assessment d2008/16705 15 Oct 2008
App D - Forensic Data Analysis d2008/16706 15 Oct 2008
App E - Reporting Flowchart d2008/16707 29 Sep 2009
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