Fraud and corruption prevention
Curtin University has zero tolerance for any fraudulent or corrupt conduct.
To this end, the University has adopted a clear framework for controlling the risks of fraud and corruption which is based on the Australian Standard for Fraud and Corruption Control (AS 8001:2008).
The approach is heavily focused on preventing and minimising fraud and corruption risks, with a strong emphasis on continually improving staff awareness.
Fraud and corruption control framework
The University's framework for fraud and corruption control provides a rigorous approach to managing fraud and corruption risks that may be committed:
- against the University, whether from internal or external sources; or
- by or in the name of the University.
The framework comprises three key themes:
- Prevention – pro-active measures designed to help reduce the risk of fraud and corruption occurring in the first place.
- Detection – measures designed to uncover incidents of fraud and corruption as close as possible to the time when they occur, or before they occur by identifying attempts or acts in preparation.
- Response – reactive measures designed to investigate, take any necessary corrective action, impose sanctions and remedy the harm caused by fraud or corruption.
The framework is embodied in a Fraud and Corruption Control Plan which, further to extensive consultation, was approved by the University's Planning and Management Committee on 27 May 2014.
The University has implemented/is implementing many measures designed to prevent fraudulent and corrupt activity. They include:
- The Strengthening our Culture Initiative.
- Strong management commitment.
- Resources dedicated to defining, implementing and overseeing fraud and corrupt prevention initiatives.
- Availability of various ethics and integrity-related publications for staff and students.
- Various policies and procedures that provide clear guidance to staff on matters such as fraud and corruption control and conflicts of interest / gifts, benefits and hospitality.
- Identification and management of fraud and corruption risks via a comprehensive risk assessment and risk treatment plans.
- Pre-employment screening.
- Awareness, education and training programs, aligned to meet the needs of multiple stakeholder groups.
The University employs/is putting in place a number of measures to early detect fraudulent and corrupt activity. These include:
- A University-wide fraud detection strategy incorporating continuous monitoring and data mining analytics.
- Provision of multiple avenues for individuals to report suspected fraud and corruption.
- A risk-focused Internal Audit function, which also undertakes fraud audits.
- Availability of internal Public Interest Disclosure (PID) officers and documented procedures, with staff encouraged to make protected disclosures involving suspected improper conduct.
- Periodic reviews by qualified external service providers to review high risk corporate system data and identify any potential fraudulent or corrupt behaviour.
Key response strategies in place/in progress in the University for dealing with detected fraudulent and corrupt activity include:
- A comprehensive complaint management system which includes a central portal for reporting instances of suspected fraud and corruption.
- Availability of dedicated, experienced (internal and externally sourced) resources for investigating suspected fraud and corruption who operate in accordance with defined investigation standards.
- An independent disciplinary system for dealing with staff who have been found to have committed fraud or acted corruptly.
- Reporting and analysis of fraud and corruption cases to senior management with identification of any emerging trends.
- KPIs for measuring the incidence of fraud and corruption in the University.
- Maintaining relationships with key external oversight and regulatory bodies in relation to the reporting and investigaton of fraud and corruption matters.
- Legal processes and insurance to recover losses in the event that the University suffers a financial loss.
- Implementation of control improvements post-investigation, and independent follow-up to ensure new/revised controls are operating effectively.