1. Purpose

1.1 This policy affirms the University’s commitment to preventing and detecting fraudulent, corrupt, unlawful, negligent or improper conduct.

1.2 The University considers that fraud and corruption control is an integral component of its overall risk and compliance management framework and plans for and resource activities accordingly, consistent with the University’s relevant Codes of Conduct and is consistent with AS ISO 37003:2025 Fraud Control Management Systems.

1.3 This policy is based on the guidelines and principles of the Financial Accountability Act 2009 (Qld), Crime and Corruption Act 2001 (Qld) (CC Act), AS ISO 37003:2025 Fraud Control Management Systems (the Australian Standard) and the Queensland Crime and Corruption Commission’s (CCC) Fraud and Corruption: Best Practice Guide.

1.4 This policy must be read in conjunction with the linked Fraud and Corruption Control - Procedures.

2. Scope and application

2.1 This policy applies to all staff, students, contractors or consultants, strategic partners, third party service providers, controlled entities, volunteers, affiliates and members of University decision-making or advisory bodies, including Council and its committees.

2.2 The University is identified as a statutory authority under the Crime and Corruption Act 2001 (Qld) and falls under the jurisdiction of the Queensland Crime and Corruption Commission (CCC). This requires that any University conduct that could be classified as corrupt conduct is reported by the Vice-Chancellor and President, as the University’s Chief Executive Officer (or public official). The Vice-Chancellor and President has delegated this duty to the Director, People and Culture.

2.3 University activities and operations undertaken outside of Queensland can be subject to similar fraud and corruption legislation and regulation in those jurisdictions. In these cases, the requirements in those jurisdictions must be complied with in addition to any obligations under Queensland law.

2.4 This policy does not apply to notification to the CCC regarding the conduct of the Vice-Chancellor and President, which is managed in accordance with the Complaints about the Vice-Chancellor and President (Crime and Corruption Act 2001, s 48A) - Governing Policy.

3. Definitions

3.1 Refer to the University’s Glossary of Terms for definitions as they specifically relate to policy documents.

Affiliate refers to Academic title-holders, visiting academics, emeritus professors, adjunct and honorary title-holders, industry fellows and conjoint appointments.

Fraud refers to dishonest activity causing actual or potential financial loss to any person or entity including theft of monies or other property by employees or persons external to the entity and where deception is used at the time, immediately before or immediately following the activity. This also includes the deliberate falsification, concealment, destruction or use of falsified documentation used or intended for use for a normal business purpose or the improper use of information or position for personal financial benefit.

Fraud Control Management System means the set of interrelated or interacting elements of an organisation that establish policies and objectives and processes to achieve those objectives consistent with Australian Standard AS ISO 37003: 2025 Fraud Control Management Systems.

Corruption is dishonest activity in which a director, executive, manager, employee or contractor of an entity acts contrary to the interests of the entity and abuses their position of trust in order to achieve some personal gain or advantage for themself or for another person or entity. The concept of ‘corruption’ can also involve corrupt conduct by the entity or a person purporting to act on behalf of and in the interests of the entity, in order to secure some form of improper advantage for the entity either directly or indirectly.

Corrupt conduct is defined as per section 15 of the Crime and Corruption Act 2001 (Qld).

4. Policy statement

4.1. The University recognises that fraud and corruption management is an integral part of good governance and management practice. The University has an Averse appetite to and zero tolerance for fraud and corruption. The University is committed to managing its fraud and corruption risks and to combatting and reducing the incidence of such activities across all of its operations and activities. This policy is consistent with the Staff Code of Conduct – Governing Policy, the University Risk and Compliance Management – Governing Policy and relevant legislation and standards.

5. Principles

5.1 Approach to fraud and corruption

5.1.1 The University is committed to implementing effective controls and treatments to prevent, avoid or eliminate the risks, so far as reasonably practicable, of such behaviour and ensuring continuing organisational integrity and transparency in all University activities.

5.1.2 The University Risk Classification Table (login required) reflects a structured classification and hierarchy of risks to ensure consistent risk identification and management across the University. At the core of this are five risk classes, which are further comprised of underpinning risk categories and risk types. Fraud and corruption risks have been captured as follows:

(a) Risk Class: Operational Risks

(i) Risk Category: Fraud & Corruption

• Risk Type: Internal (Staff)
• Risk Type: External (Admissions)
• Risk Type: External (Third Party Vendor/Supplier)
• Risk Type: Academic integrity and student misconduct
• Risk Type: Research integrity and misconduct

5.1.3 The University aims to develop and maintain an organisational culture of honesty and integrity.

5.1.4 The University puts in place processes that ensure effective prevention, detection and management of fraud and corruption.

5.1.5 The University encourages, supports and protects persons who report suspected fraud and corruption.

5.2 Fraud and corruption control

5.2.1 In addition to this policy, the University maintains a Fraud and Corruption Control Plan (login required) and the Fraud and Corruption Control – Procedures. These documents form part of the University’s fraud control management system which is an integral part of the University’s risk management framework.

5.2.2 Diagram 1 provides an overview of the key components of fraud and corruption control.

Diagram 1 – Fraud and Corruption Control

5.3 Fraud risk protected disclosures

5.3.1 When a staff member is aware of, or suspects, fraudulent or corrupt conduct, they must report these suspicions immediately. Staff should do so in accordance with the Fraud and Corruption Control – Procedures.

5.3.2 Confidentiality must be maintained throughout any investigative process.

5.3.3 The University ensures protection of those reporting suspected instances of fraud and corruption and ensures that this policy is well understood by the University community.

5.3.4 The University ensures that there are adequate means, for reporting suspected instances of suspicious, illegal or unethical conduct, and that these means are widely known and available. This includes the means for anonymously reporting of such conduct.

5.4 Monitoring and review

5.4.1 Following the detection of fraud or corrupt conduct, the organisational unit manager, in consultation with the Director, Governance and Risk Management, reassesses the adequacy of the internal control environment and identify actions required to strengthen controls.

5.5 Fraud risk reporting

5.5.1 The preparation of fraud and corruption risk reporting is facilitated by the Director, Governance and Risk Management (DGRM) through the biannual risk management and quarterly compliance management processes. In addition to data obtained through the risk and compliance management and risk assessment processes, this reporting consolidates, and analyses incident data collected and reported by:

(a) People and Culture (staff misconduct and CCC referrals);

(b) Office of Research (research integrity);

(c) Academic Integrity Unit within Centre for Support and Advancement of Learning and Teaching (CSALT) (academic integrity);

(d) Financial Services (procurement/financial fraud); and

(e) Student Services & Engagement (admissions and student misconduct)

5.5.2 This reporting is provided to the University Executive Committee (ExCom), Academic Board (AB), the Audit and Risk Management Committee (ARMC), and the University Council on the following basis:

6. Authorities and responsibilities

6.1 As the Approval Authority, Council approves this policy in accordance with the University of the Sunshine Coast Act 1998 (Qld).

6.2 As the Responsible Executive Member of this policy the Vice-Chancellor and President can approve procedures and guidelines to operationalise this policy. All procedures and guidelines must be compatible with the provisions of this policy.

6.3 As the Designated Officer of this policy the Director, Governance and Risk Management can approve associated documents to support the application of this policy. All associated documents must be compatible with the provisions of the policy.

6.4 This policy operates from the last amended date, superseding all previous versions of the fraud and corruption control policy, with no further operation from this date.

6.5 All records relating to the fraud and corruption control must be stored and managed in accordance with the Records Management - Procedures.

6.6 This policy must be maintained in accordance with the University Policy Documents – Procedures and reviewed on a standard 5-year policy review cycle.

6.7 Any exception to this policy to enable a more appropriate result must be approved in accordance with the University Policy Documents – Procedures prior to deviation from the policy.

6.8 Refer to Schedule C of the Delegations Manual in relation to the approved delegations detailed within this policy.

6.9 The following authorities and responsibilities are delegated under this policy:

7. Appendices and supporting documents

Fraud and Corruption Control Plan (login required)