Policies for the Prevention of Fraud and Mismanagement

PURPOSE

The Prevention of Fraud and Mismanagement Policy outlines measures taken by the Institute to prevent fraud and mismanagement.

SCOPE

This policy applies to all members of staff.

STATEMENT

Rosary Tertiary Institute is committed to dealing with fraud prevention. The Professional Conduct of Staff is the principle guide for dealing with fraud prevention. It states that staff members are required to inform themselves about fraud controls, to inform the institute if they suspect acts of fraud and that if a staff member commits an act of fraud it will be investigated.

This Policy is supported by the Theft, Fraud and Corrupt Conduct Procedure, which summarises the procedures to be used once an allegation of fraud is made to a senior staff member.

PROFESSIONAL CONDUCT OF STAFF

• Staff Responsibilities

1. Rosary Tertiary Institute seeks to create a safe and rewarding learning and working environment based on the principles of the Catholic faith, justice, equity, harmony, tolerance and pursuit of excellence while protecting the resources of the Institute and respect for individuals, the law and the governance of the Institute.
2. In circumstances where staff conduct does not meet the standards set out in this policy and related procedures, senior members of staff may speak with the individual concerned in an attempt to remedy the situation. In cases where the misconduct exceeds the scope of authority, the matter may be referred to the proper civil authority.

• Personal and Professional Behaviour

1. Staff must uphold the values of the Institute outlined in the Prospectus.
2. Staff must maintain a high standard of conduct and level of performance while demonstrating courtesy, equity and fairness in dealing with staff, students, contractors, visitors and members of the public. The rights, duties and aspirations of others will be respected at all times.
3. Staff must perform their duties in a professional manner with skill, care and diligence and with a proper utilisation of their authority.
4. Staff must treat others fairly and with respect and must not engage in any harassing, bullying or discriminatory behaviour.
5. Staff in administrative positions will maintain, as far as possible, a safe and orderly working environment.
6. Staff must endeavour to ensure that their actions or decisions do not harm the health, safety and well-being of themselves or others, nor affect their work performance or that of others and must comply with the STAC Occupational Health and Safety Standards.
7. Staff in management positions must ensure that all staff have the necessary qualifications to fulfil the responsibilities of the positions they occupy.
8. Staff must ensure that relationships with students are professional, respectful and trusting.
9. Staff must acknowledge that they have a responsibility to protect the interests of students and to acknowledge and resolve any conflicts of interest that may arise; to respect staff-student relationships and to accept the obligations involved in their responsibilities.

• Institute Finances

1. Staff will maintain the highest standards of integrity in financial matters and, particularly, will comply with the requirements relevant to financial management legislation and the Institute’s financial procedures which have been taken from the rule and constitution of the Dominican Sisters of Wanganui.

• Protection of Institute Resources

1. Staff must utilise and maintain Institute equipment and resources in an economical and efficient manner and exclusively for Institute purposes;
2. Staff must secure Institute equipment and resources against misuse or theft;
3. Staff must follow all procedures governing the use of the Institute’s electronic communications systems, and avoid excessive personal use of the Institute’s electronic communications systems which incurs additional cost to the Institute.
4. Staff must ensure the protection of the privacy of others and the maintenance of appropriate confidentiality with regard to personal matters and information acquired in the course of their employment and will use information only for purposes related to work
5. Staff must maintain the confidentiality of official and personal information for which they are responsible and take all precautions to prevent all unauthorised access to or misuse of the Institute’s records and information
6. Staff must comply with all relevant copyright and records management policies and procedures.

• Respect for the Law and Tertiary Institute governance
  1. Staff must comply with all laws, regulations, codes, policies and procedures.
  2. Staff may report to management any behaviour that is in violation of any law, rule or regulation or that represents improper conduct, mismanagement of resources, or is a danger to public health and safety.
  3. The Institute does not tolerate improper conduct by Institute Staff or Board members, nor the acceptance of reprisals against those who offer to disclose such conduct.
  4. The Institute recognises the value of clarity and accountability in its administrative and management activities and supports the making of disclosures that reveal corrupt and improper conduct.
  5. The Institute will take the necessary and practical steps to protect individuals who make disclosures as described above in article 5.4 from any detrimental action in response for making the disclosure. The Institute will protect the confidentiality of the disclosure and the identity of the person who made the disclosure and allow procedural fairness to all parties concerned, including the one who is subject to the disclosure.
  6. Staff will not harass or take rash action in response to actual or suspected disclosures or participation in an investigation into such a disclosure.

6. Conflict of Interest

6.1 Staff will act with best interests of the Institute in mind when carrying out the duties of their position and must not allow their private interests or the interests of others inhibit them in this obligation.

7. Gifts

7. 7.1 All gifts to staff will be managed according to the Constitutions of the Dominican Sisters of Wanganui.

8. Academic Integrity

9. 8.1 Staff will maintain a high ethical and academic standard according to the Constitutions of the Dominican Sisters of Wanganui.

9. Misconduct

9.1 The Institute will carry out any necessary disciplinary action for misconduct and unsatisfactory performance according to the Rule and Constitutions of the Dominican Sisters of Wanganui.

9.2 Disciplinary action will be at the discretion of the local Prioress and/ or Mother Prioress General, as per the Rule and Constitutions of the Dominican Sisters of Wanganui.

9.3 Requests for review of a disciplinary action will be managed according to the Rule and Constitutions of the Dominican Sisters of Wanganui.

10. Theft, fraud and corrupt conduct

10.1 The Institute does not tolerate fraud or corrupt activity.

10.2 All staff are required to familiarise themselves with the Rule and Constitutions of the Dominican Sisters of Wanganui and fulfil their duties in accordance with them.

10.3 All Staff are expected to report any suspected fraudulent or corrupt activity to the Director.

B.  Theft, Fraud and Corrupt Conduct Procedure

1. Approach to theft, fraud and corrupt conduct

1.1 The Institute is committed to preventing occurrence of theft, fraud and corrupt conduct. This will be achieved through:

• Risk management strategies
• Prevention strategies
• Detection strategies
• Response strategies

2. Risk Management

2.1 Risk management will be carried out in accordance with RTI’s Risk Management Policy.

3. Preventative controls

3.1 To prevent theft, fraud and corrupt conduct, the Institute will have internal controls to avoid this. These will include: financial delegations, lines of authority and accountabilities, segregation of duties, approval processes, etc.

3.3 The Director will inform staff of how to prevent and report suspected fraud and corrupt conduct.

3.4 Supervisors will ensure that the following staff are familiar with and comply with the Rule and Constitutions of the Dominican Sister of Wanganui:

• Staff delegated to make financial decisions
• Staff delegated to make staff appointment decisions
• Staff delegated to manage contracts

3.5 Staff delegated to engage external contractors or suppliers will ensure that the contractors or suppliers are financially sustainable individuals or businesses before engaging their services.

3.6 The Risk Management Team will provide staff with a risk management tool to enable staff responsible for engaging contractors and suppliers to identify the level of risk and the level of critical examination required for each procurement activity.

4. Fraud detection controls

4.1 The Director will analyse the accuracy of all transactions.

4.2 The Director will ensure that those staff with delegated financial duties will analyse transactions for approval of the following:

• Validity
• Accuracy
• Invoice coding
• Invoices addressed to Rosary Tertiary Institute
• Goods and services tax (GST) calculations

4.3 The Director will give a monthly account of her receipts and expenditure to the local Prioress and conduct an annual internal financial audit, as per the Constitutions of the Dominican Sisters of Wanganui.

5. Reporting of theft, fraud and corrupt conduct

5.1 A staff member who suspects that an act of theft, fraud or corrupt conduct may be about to occur, is occurring or has occurred must report such suspicions to their head of department, the Director, the local Prioress or the Mother Prioress General.

5.2 On receiving a report of suspected theft, fraud or corrupt conduct, the head of department or Director will:

• Record the time, date and details of the report made
• Refer the report (including anonymous reports where there is adequate supporting information) to the local Prioress or Prioress General immediately and before any investigation of such allegations is undertaken.

5.3 Where a report of suspected theft, fraud or corrupt conduct made involves a senior officer of the Institute, the Director will refer the report to the local Prioress or, in case of her unavailability, the Prioress General.

5.4 The Institute’s public information will inform individuals who are not staff or students of the Institute how to file a complaint regarding improper conduct, detrimental action or other corrupt conduct or misconduct by the Institute, its staff and its officers.

5.5 Where the local Prioress or Prioress General determine that an allegation as a deliberate false allegation of fraud, theft, or corrupt conduct, the staff member who made the allegation will be dealt with according to the Rule and Constitutions of the Dominican Sisters of Wanganui.

6. Investigation

6.1 The Director will assess whether a report of suspected fraud, theft or corrupt conduct warrants further investigation.

6.2 Where a preliminary investigation of allegations of theft, fraud or corrupt conduct by a staff member is required, the Director will appoint investigation officers and provide them with reference terms. The investigation officers will conduct all investigations according to the Rule and Constitutions of the Dominican Sisters of Wanganui.

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6.3 Where an external contractor to the Institute is involved in suspected theft, fraud or corrupt conduct, the Director will notify all departments who have engaged the external contractor and all other relevant areas of the Institute. At the conclusion of the preliminary investigation, the Director may:

• Take no further action
• Refer the matter to Legal Services
• Conduct a full investigation
• On the advice of the Mother Prioress General, report the theft, fraud or corrupt conduct to the police for further action where evidence of theft or fraud is found to be of a serious nature and a prima facie case has been established.

7. Insurance cover

7.1 The Director is responsible for ensuring that the Institute’s management liability insurance coverage is current and will cover the Institute for the risk of loss incurred from theft, fraud or corrupt activity and externally instigated fraud.

8. Statutory reporting requirements

8.1 Where alleged theft, fraud or corrupt conduct have been found to involve the embezzlement of money, stores or property, the Director will report the matter to the Victorian Minister of Tertiary Education and Auditor-General of Victoria as required under the Financial Management Act 1994 (Vic).

9. Review of procedures and controls

9.1 The Director will review internal controls relating to theft, fraud and corrupt conduct.

9.2 The Director will follow up with management responsible for the area affected by theft, fraud or corrupt conduct to ensure that recommendations have been carried out within appropriate timeline.

9.3 In all instances where there is a report of theft, fraud or corrupt conduct, the Director will review the procedures and controls in operation within the department and advise the Director of this review, including any action taken to address any inadequacies discovered.

10. Records

10.1 The Administrator will retain the records of all theft, fraud and corrupt conduct investigations.

11. Confidentiality

11.1 A staff member who is involved in or becomes aware of theft, fraud or corrupt conduct investigation will retain the details and investigation results confidential, subject to the needs of the Institute, the Director and the police during their investigation.

11.2 Staff will not discuss or report any suspected or proven occurrence of theft, fraud or corrupt conduct to the media.

This policy has been benchmarked with the Privacy Policy of Eastern College Australia