FRAUD POLICY

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Introduction

To provide a framework for members in the prevention, detection, reporting and management of fraud and corruption in the workplace, including within U3A noosa, its partners and agents and its affiliated entities.

Purpose

This policy describes the principles and procedures for all members and visitors to U3A noosa to understand and act to prevent fraud and corruption at U3A Noosa together with the setting of internal controls and reporting of any fraudulent behaviour.

Scope

This policy applies to:

  1. All members of U3A noosa whether full-time members, visiting members, volunteer helpers, tutors or casual visitors.
  2. Members of Committee or other U3A organisations or contractors.
  3. Visiting lecturers, tutors or consultants.
  4. Individuals who are engaged in providing services to U3A noosa or receiving services from U3A noosa, such as students, contractors or consultants.

The policy does not address all possible situations that may arise within the wide range of activities carried out by and through U3A noosa but provides a process that can be applied in most situations.

Policy Statement

U3A noosa recognises that the management of fraud and corruption is an integral part of good governance and management practice, and adopts the standards contained in the Standard AS8001-2008: Fraud and Corruption Control and the Crime and Corruption Act 2001.

U3A noosa shall develop and maintain a culture of honesty and integrity within the organisation and put in place processes that ensure the effective prevention, detection and management of fraud and corruption. To that end, U3A noosa has adopted a zero-tolerance approach on fraud and corruption in all U3A noosa activities, which is consistent with the Code of Conduct and the law.

Principles

In support of the above obligations and the Standard on Fraud and Corruption Management, this policy is based on the following principles:

  1. A sound ethical culture
    U3A noosa will ensure that it has a sound and sustainable ethical culture through a process of awareness training, benchmarking and monitoring.
  2. Senior management commitment
    Senior management will demonstrate a high level of commitment to controlling the risk of fraud and corruption within and by U3A noosa.
  3. Management and staff awareness
    Every member and office holder of U3A noosa should have a general awareness of fraud and corruption and how they should respond if this type of activity is detected or suspected.
  4. Fraud and corruption control planning
    U3A noosa must have an appropriate Fraud and Corruption control strategy, which is to be reviewed and amended as necessary. Accountability for the implementation and monitoring of the strategy should be specifically allocated.
  5. Internal controls
    U3A noosa must have in place effective internal controls to protect it against the risk of fraud and corruption.
  6. Fraud and corruption detection
    U3A noosa will implement systems aimed at quickly identifying instances of fraud and corruption in the event that prevention strategies fail.
  7. Reporting mechanisms
    U3A noosa will ensure that there are adequate means for reporting suspicious or known illegal/unethical conduct, and that these means are widely known and available.
  8. Protection of persons making reports of fraud and corruption
    U3A noosa will ensure active protection of those reporting suspected instances of fraud and corruption and will ensure that this policy is well understood by U3A Noosa community.
  9. Dealing with detected or suspected fraud and corruption
    In the event that fraud or corruption is detected or suspected, U3A noosa will adopt a comprehensive approach to the subsequent investigation, disciplinary proceedings, prosecution or recovery action.

Procedures

Fraud and Corruption Management Responsibility

The President and the executive members of the Management Committee are responsible for the implementation of this policy through an appropriate fraud and corruption management system and effective internal control structure. In accordance with the provisions of the Crime and Corruption Commission’s (CCC’s) 10 element model for Fraud and Corruption Control, U3A Noosa’s framework will consist of:

  1. U3A noosa-wide policy;
  2. Risk assessment;
  3. Internal controls;
  4. Internal reporting;
  5. External reporting;
  6. Public interest disclosures;
  7. Investigation;
  8. Code of Conduct;
  9. Staff training and education; and
  10. Client and community awareness.

Internal Controls

The President is responsible for ensuring that appropriate and effective internal control systems are in place for the prevention and detection of fraud and corruption. The President is supported by the Management Committee in ensuring appropriate and effective control systems are operating.

These systems will include requirements for fraud and corruption prevention in all aspects of U3A noosa activity, including financial, administration, information communication technology, and academic areas. An internal control system consists of the policies, structure, procedures, processes, tasks and other tangible and intangible factors that enable U3A noosa to respond appropriately to operational, financial, compliance or any other type of risk.

Managers and supervisors are responsible for daily operations and for maintaining cost effective internal controls within their individual areas of responsibility. All managers and supervisors must share responsibility for the prevention and detection of fraud.

Equally, all members and officers of U3A noosa must share the responsibility for the prevention and detection of fraudulent and corrupt activities, which includes the reporting of suspected instances of such activity.

Internal Reporting

Reporting plays a crucial role in controlling fraud and corruption. Accordingly, all members are encouraged to report suspected or known instances of fraud and corruption.

Where an individual has an honest and reasonable belief that a U3A noosa member may have engaged in, is engaging in or will engage in any of the conduct outlined in the definitions of Public Interest Disclosures, information concerning that conduct should be reported to U3A noosa. A report made to a person other than an appropriate entity and not made in accordance with this policy may not be afforded the protection of the legislation.

Reports of Public Interest Disclosures should be made verbally or in writing email to:

  1. the President
  2. any member of the Management Committee
  3. directly to the Fraud and Corruption Reporting Hotline

If a report is made to any of the individuals or entities indicated in (1) to (3) above, the report is to be referred, in writing, to the Director (Integrity and Professional Conduct) as soon as is practicable.

 

External Reporting

U3A noosa must have mechanism (SharePoint) in place for assessing fraud and corruption matters and determining its obligations for reporting them to relevant external agencies.

External agencies to which reports on fraud and corruption are made will be determined by legislative requirements, and may include such agencies as the CCC, the Queensland Police Service, and the Queensland Audit Office.

The President or their nominee will be responsible for determining any referral of fraud and corruption allegations or associated matters to the CCC and/or other appropriate external agencies.

Public Interest Disclosures

  • U3A noosa will provide protection for individuals making a disclosure and natural justice for those who are the subject of disclosures.

Investigations

An initial assessment of fraud and corruption allegations and determination that an investigation will be carried out will be managed on a case-by-case basis by an independent person. This person may consult with other appropriate U3A noosa officers or external experts as necessary, whilst maintaining the confidentiality of the individual making the report. The CCC Facing the Facts describes the various steps involved in conducting a formal investigation as follows:

  1. determining the scope and nature of any investigation
  2. confirming the responsibilities and powers of the investigator
  3. conducting the investigation
  4. gathering the evidence
  5. concluding the investigation

The Investigations Officer will provide an initial report and recommendation to the Committee.

Instances of fraud and corruption on the part of individuals other than members will be managed in accordance with contractual conditions specified in their association with U3A noosa, following an investigation process conducted by U3A noosa as outlined in the investigations section of the Disciplinary Action for Misconduct or Serious Misconduct Procedure.

U3A noosa will make accessible to its stakeholders and the wider community its Code of Conduct, its Vision, Mission and Values Statements, and other policies and procedures concerning the quality assurance procedures U3A noosa has adopted to ensure that its officers act ethically and honestly and are socially responsible.

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