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(1) This Instruction provides details on how fraud and corruption investigations are conducted at RMIT. It aligns with expectations for professional, fair, thorough and skilled investigations outlined in Australian Standard AS8001:2021 Fraud and Corruption Control. (2) Authority for this document is established by the Fraud and Corruption Control Policy. (3) This Instruction applies to fraud and corruption investigations conducted anywhere across the (4) Not all allegations of fraud or corruption are investigated internally by RMIT. After a preliminary assessment, the case may be referred to the police or an external agency (e.g. the Independent Broad-based Anti-Corruption Commission) by the Executive Director, Governance, Legal and Strategic Operations. (5) RMIT’s internal investigators are appropriately skilled and experienced officers who are independent of the business unit in which the alleged fraud or corruption has occurred. (6) A fraud or corruption investigation typically has the following stages: (7) There are multiple avenues within RMIT for employees, students or third parties to disclose suspected fraud or corruption, including on the Complaints Portal, to supervisors, the Whistleblower Coordinator, the Director, Risk Management, or directly to Central Complaints and Investigations. All fraud and corruption allegations are directed from these recipients to the Associate Director, Central Complaints and Investigations to triage and allocate to an investigator, or refer to an external body where required to by law. (8) Employees can seek advice from CCentral Complaints and Investigations if they are uncertain about whether to disclose an allegation of fraud or corruption to RMIT or to an external body. (9) Initial allegations are completely and accurately documented, including the components of each allegation to assist in planning the investigation. (10) Investigators determine the legislation or policies that are relevant to the suspected fraud or corruption investigation and the implications from those instruments, e.g. where criminal legislation is relevant, more stringent rules of evidence may apply, and where there is a public interest disclosure there may be additional protection offered to the person who disclosed the corruption. (11) The preliminary assessment also considers whether: (12) On the discovery of fraud or corruption, RMIT investigators: (13) The early capture of digital evidence is performed by a forensic information technology expert in accordance with the International Standard ISO/IEC 27037 Information Technology – Security Techniques – Guidelines for identification, collection, acquisition, and preservation of digital evidence. (14) Investigators prepare an investigation plan that documents: (15) Investigators may employ any of the following activities when investigating allegations of fraud or corruption: (16) Interviews are carefully planned to ensure all pertinent information is collected in a way that enhances credibility. Planning includes topics and the order in which they are covered, questions for each topic and the way they will be asked, evidence to be presented to the interviewee, and detailed knowledge of evidence that has been collected. (17) When a complaint is referred for investigation, the Central Complaints and Investigations team notify in writing the person suspected of the fraudulent or corrupt conduct (the respondent) and include: (18) Investigations of suspected fraud or corruption are conducted in a manner consistent with the principles of natural justice and procedural fairness. This means: (19) In addition to considering evidence about what occurred, consideration is given to whether the persons involved knew or should have known that the conduct was forbidden. (20) For each investigation, RMIT records: (21) Investigation records are prepared, maintained and retained in accordance with the Information Governance Policy and the Privacy Policy, and comply with the requirements for the Victorian Auditor-General’s Office and IBAC. (22) All evidence captured is recorded at the time it is collected, always held securely, and accounted for each time it is handed to another party (known as continuity of evidence or chain of custody). (23) RMIT may capture oral evidence through audio or video recordings with the knowledge of the participants and in accordance with relevant policies such as the Complaints Governance Policy, e.g. in the presence of a support person for the interviewee. (24) Recordings are made in a manner that is likely to ensure that information obtained from the interviews is admissible in court, such as having the person confirm on the recording that they have given permission for the recording. (25) Interviews may be converted to written form and preferably signed or acknowledged as true and accurate by the participants. (26) Any exculpatory evidence is recorded, i.e. evidence that is favourable to the person suspected of fraud or corruption and which may exonerate them. (27) Investigators methodically check that every element of every allegation has been properly covered in the investigation. (28) Reports of an investigation recognise the need to protect whistleblowers and exhibit fair treatment of the person who has allegedly engaged in fraudulent or corrupt conduct. (29) Reports include an executive summary, background, details of each allegation, relevant evidence collected, assessment of the evidence, conclusion and recommendations. (30) Reports include an assessment of whether there was a serious breakdown of fraud and corruption risk controls, and how these controls could be improved to prevent further incidents. (31) If there appears to be adequate evidence to support either a criminal prosecution or further investigation by the police, the investigator works with Legal Services to prepare a police brief. (32) The response to an adverse finding must be proportional to the seriousness of the fraud or corruption. (33) At the conclusion of an investigation, the findings are referred to the relevant senior officer as prescribed by the Delegation of Authority Schedule 3 – People Delegations, to determine the outcome for the employee in terms of their employment at RMIT, in accordance with relevant policies and enterprise agreements.Fraud and Corruption Investigation Instruction
Section 1 - Purpose
Section 2 - Authority
Section 3 - Scope
Section 4 - Instruction
Investigation stages
Receiving and recording an allegation
Preliminary assessment
Immediate response
Investigation activities and evidence collection
Notifying the respondent
Procedural fairness
Record keeping
Assessing evidence and reporting findings
Determining the outcome