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(1) The purpose of this policy is to encourage the highest level of integrity in organisational culture as an essential part of RMIT’s management and corporate governance framework. (2) The policy aims to promote a culture of honesty, integrity and professionalism, and reinforce RMIT’s zero tolerance for fraud and corruption. (3) The policy supports RMIT’s legislative obligations, including: (4) This policy supports RMIT’s commitment to the United Nations Sustainable Development Goals (SDG), particularly SDG 16 – Peace, Justice and Strong Institutions by reducing organisational risk and strengthening measures against fraud and corruption. (5) RMIT’s fraud and corruption control system aligns with the Australian Standard for Fraud and Corruption Control (AS8001:2021) and is comprised of: (6) This policy defines the illegal or unacceptable, high risk behaviours that constitute fraud and corruption, and reinforce RMIT’s position of no tolerance for such conduct. It outlines the principles guiding the prevention, detection and management of fraud and corruption at RMIT, and lists the responsibilities of those in its scope. (7) This policy applies to RMIT University Council members, employees, researchers, students and contractors of the RMIT Group, and any other persons working with or on behalf of the (8) The provisions in this policy take precedence over other RMIT policies when it comes to the improper conduct of employees if there is the potential that the matter may need to be investigated by the police, the Independent Broad-based Anti-corruption Commission (IBAC), or other external regulatory agency. (9) At RMIT, corrupt conduct is any conduct that: (11) RMIT expects, encourages and supports employee ethical behaviour, and does not tolerate fraud or corruption. (12) RMIT maintains trust with the public by exhibiting the highest standards of integrity in its operations and decision making. It recognises that fraud and corruption can create reputational and financial damage to RMIT which undermines public confidence, employee and student productivity and morale. (13) RMIT takes a risk-based approach to managing fraud and corruption through the risk management framework which requires all risks relating to fraud and corruption to be identified, assessed, responded to and monitored on an ongoing basis. (14) The effectiveness of the mechanisms used to control fraud and corruption risks are regularly evaluated and reported to the Audit and Risk Management Committee. (15) Fraud and corruption is one of the broad risk domains in RMIT’s comprehensive risk management framework. (16) Senior managers in high risk areas apply RMIT’s risk management tools and activities to identify potential opportunities for fraud and corruption in their area of responsibility. (17) Identified fraud and corruption risks are recorded in the enterprise risk management system. Identified risks inform the development of prevention strategies. Examples of high risk areas and activities are included in Schedule 1 – Examples of Corrupt Conduct, Fraud, Public Interest Disclosures and High Risk Areas. (18) RMIT prevents fraud and corruption with: (19) RMIT undertakes activities that recognise whether fraud or corruption has occurred or is occurring. These include: (20) Staff investigating other types of complaints, such as employee or student misconduct, are trained in recognising complaints about fraud and corruption and the need to notify Central Complaints and Investigations if there is a financial element to the misconduct they are investigating. (21) RMIT ensures procedural fairness when dealing with fraudulent or corrupt conduct allegations. Refer to the Fraud and Corruption Investigation Instruction for details on the investigation process. (22) Investigations of potential fraud and corruption are handled by suitably qualified and trained employees or contractors, and in accordance with the relevant legislation, enterprise agreement and RMIT policies and procedures. (23) The preliminary assessment of an allegation may determine that the matter needs immediate referral to the police or the Victorian Independent Broadbased Anti-Corruption Commission for them to conduct the investigation (see clause 29 below). (24) The outcome for employees found to have engaged in fraud or corruption is determined: (25) RMIT may take reasonable legal action to reclaim any resources misappropriated through fraud or corruption where appropriate and determined by RMIT’s General Counsel. (26) RMIT complies with the laws of the countries in which it operates. Where a conflict arises between legislative requirements that apply to RMIT operations relating to fraud and corruption control and public interest disclosure, RMIT adopts the more onerous requirement. (27) RMIT’s Complaints Portal enables employees to report suspected fraud or corruption to the Central Complaints and Investigations Unit. (28) Disclosures of suspected fraud or corruption can also be made to an independent third party, such as Stopline, Victorian Ombudsman and the Independent Broad-based Anti-corruption Commission, depending on the scale and significance of the allegation. (29) Persons disclosing suspected fraud and corruption can request whistleblower protections in accordance with the Public Interest Dislcosures Act 2012 (Vic). Refer to the Whistleblower Procedure for details about what can be disclosed as a ‘public interest disclosure’, to whom, and the protections provided by the Public Interest Disclosures Act. (30) RMIT University Council has overall accountability for controlling RMIT’s fraud and corruption risks, and receives an annual report on fraud and corruption matters through the Audit and Risk Management Committee. (31) The Audit and Risk Management Committee is responsible for: (32) The Vice-Chancellor’s Executive is responsible for: (33) The Chief People Officer is responsible for: (34) The Chief Information Security Officer is the delegated information security management and system officer responsible for: (35) The Executive Director, Governance, Legal and Strategic Operations is the delegated Whistleblower Coordinator and is responsible for: (36) The Associate Director, Central Complaints and Investigations is responsible for: (37) The Director, Risk Management is responsible for: (38) The Internal Audit team are responsible for: (39) All employees are responsible for: (40) Members of RMIT’s senior executive are responsible for ensuring compliance with this policy within their area of responsibility. (41) Non-compliance with this policy may result in disciplinary action, including summary termination of employment or engagement, and referral to law enforcement agencies. (42) Refer to the following documents which are established in accordance with this policy:Fraud and Corruption Control Policy
Section 1 - Purpose
Section 2 - Overview
Section 3 - Scope
Section 4 - Policy
Principles
Identifying fraud and corruption risks
Prevention
Detection
Response
Where to report suspected fraud or corruption
Responsibilities
Compliance
Section 5 - Procedures and Other Policy Documents
Top of PageSection 6 - Definitions
Detrimental action (defined by the Public Interest Disclosures Act 2012)
Action causing injury, loss or damage; intimidation or harassment; or discrimination, disadvantage or adverse treatment in relation to a person's employment, career, profession, trade or business, including the taking of disciplinary action. It does not include management action in relation to an employee whistleblower taken for a substantial reason other than the employee having made a public interest disclosure. See Whistleblower Procedure.
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 a criminal offence or reasonable grounds for dismissal, if proved.