The University Policy on Fraud and Corruption, in conjunction with the Guidelines for Dealing with Fraud and Corruption at UWA, clarifies the responsibilities of all University staff in creating an honest, ethical and professional workplace, and outlines the requirements and protocols for raising issues of suspected fraud and corruption and the conducting of investigations, including referral to the Corruption and Crime Commission of Western Australia.
Fraudulent and corrupt conduct generally involves behaviour that is deliberately dishonest or deceitful and involves the abuse of trust which leads to a person gaining a benefit from these types of actions. The Guidelines for Dealing with Fraud and Corruption at UWA may assist in identifying activities considered to be fraudulent or corrupt conduct within the University. Examples include unauthorised use of University property, undeclared conflicts of interest, falsifying or manipulating research data, misrepresenting a person’s involvement in research/projects, or making false claims of expenses or leave entitlements.
Employees at all levels within the University have a duty to report any act or situation that may be suspected as fraudulent or corrupt as soon as they are aware of these circumstances. If you believe that a person is involved in fraudulent or corrupt activities, you should follow the University’s normal channels for reporting misconduct. However in some circumstances, or if you are afraid of repercussions, it may be necessary to raise an issue directly with a senior manager, or one of the University’s Public Interest Disclosure Officers to discuss the matter. See 3.2 below for further information and Appendix 2 for contact details.
University Policy on: Fraud and Corruption
governance.uwa.edu.au/policy/UP08/4
Guidelines for Dealing with Fraud and Corruption at UWA
hr.uwa.edu.au/2215113
The University is bound by the WA Public Interest Disclosure Act which permits complaints about University staff to be investigated on a protected and, if necessary, anonymous basis. Because the University falls under this Act, staff and students who report such behaviour to one of the University’s Public Interest Disclosure Officers are provided with protection for doing so. Those who are alleged to have committed corrupt or other improper behaviour are also protected by the Act’s provisions on confidentiality.
The University’s policy on Public Interest Disclosure will be released in 2014 and will be located at
governance.uwa.edu.au/2374334
The University Public Interest Disclosure Officers are the Director of Legal Services, Director of Human Resources, and Manager, Complaints Resolution. Contact details are in Appendix 2.
The University is committed to providing and maintaining safe workplaces, plant and systems of work as far as reasonably practicable. All activities are required to be properly planned and conducted in accordance with legislative, industry and relevant standards to ensure the safety, health and welfare of all participants and others.
All persons who organise or conduct activities for or on behalf of the University are responsible for acquiring and keeping up to date knowledge of safety and health matters and ensuring that appropriate resources and processes for eliminating or minimising risks from hazards are in place. Effective communications and compliance through documentation, inspection and reviewing of activities is required in order to demonstrate due diligence.
All staff and students are required to take reasonable care of their safety and health and that of others, follow all safety and health policies and procedures and report all known or observed hazards, incidents and injuries.
Safety and Health – Policies, Procedures and Guidelines
safety.uwa.edu.au/1720806
A world-class organisation is recognised by its capacity to develop and harness the capabilities of its staff and resources through effective management with a commitment to sustainability principles and practices. The University embraces this direction. The UWA Operational Priorities Plan for 2009-2013 establishes objectives for a sustainable future for the University.
The University aims to:
Under the direction of the Vice Chancellor’s Committee for Sustainable Development, environmental sustainability becomes the responsibility of all managers, staff and students. This includes the management and planning in areas of energy, recycling, water, transport, built form, landscape, communication, and engagement and opportunities to engage with teaching and research.
Sustainable Development Plan
sd.fm.uwa.edu.au/1881514
Members of the University are expected to use all University facilities and equipment efficiently, carefully and honestly. Resources should be used economically, secured against theft or misuse and waste avoided. These resources should not be used for personal purposes unless express permission has been granted in accordance with University policy.
University Finance Manual
finserv.uwa.edu.au/2152805
University Policy on: Professional and Consultative Work
governance.uwa.edu.au/policy/UP07/204
University Information Technology and Communications Policies and Regulations
is.uwa.edu.au/1785606
The University places a high value on integrity, professionalism and respect for others. While the University does permit moderate use of UWA IT facilities for private use, members of the University must be particularly conscious of these values when accessing the internet, sending and receiving email, and using social networking sites. Inappropriate use of information technology, in particular, accessing or disseminating offensive material via the internet or email contravenes University Regulations and may be unlawful. The University has formally adopted a number of IT Policies and, unless otherwise indicated, they are binding upon all members of and visitors to the University. Disciplinary action may apply to staff or students found in breach of the University’s IT Policies and the Computer and Software Use Regulations.
University Information Technology and Communications Policies and Regulations
is.uwa.edu.au/1785606
University Policy on: Use of Email
governance.uwa.edu.au/policy/UP07/43
The University recognises that social media is a term which encompasses the various activities that integrate technology, social interaction, and the construction of words, pictures, videos and audio. For many people, participation in social media technologies is an integral aspect of their professional and social lives, which may lead to a blurring of the public face and private identity of employees.
The University has a particular concern regarding the ease with which professional distance and personal use can be blurred. Employees’ use of social media, either in a professional or personal capacity, can challenge the privacy, security and reputations of other employees, students and/or The University. Therefore, individual employees of the University are obliged to:
Any activity which represents a failure to meet these obligations may be determined as misconduct or serious misconduct, resulting in disciplinary action including termination of employment.
The authorised use of media forums, including social media, in any authorised capacity on behalf of the University to announce achievements and public comments within an area of expertise, is outlined in 3.9 ‘Public Comment’ below.
The Social Media policy outlines appropriate participation in social media communication, examples of social media technology, and of situations that may be considered misuse. Employees have a responsibility to familiarise themselves with this and other related IT policies.
University Policy on: Social Media
governance.uwa.edu.au/policy/UP11/22
Public comment includes public speaking engagements, comments on radio or television, and expressing views in letters to newspapers or in books, journals or notices, or where it might be expected that the publication or circulation of the comment may spread to the community at large, such as through social networking websites.
Staff members are encouraged to comment publicly in relation to their area of professional expertise. When staff members are representing the University the highest ethical and professional standards are expected of them primarily due to the sensitivity of some issues within the community.
Staff members in their capacity as private citizens have a right to make public comments. If a staff member is publicly commenting on an issue not within their professional expertise, the staff member must make it clear that the comment is being made in a private capacity.
UWA Guidelines for Media Engagement
staff.uwa.edu.au/2052991
Risk Management is a formal process for identifying, analysing, evaluating and treating the uncertainty associated with any activity, process, function or service undertaken by the University. Formal Risk Management aids decision-making by taking account of uncertainty and the effect this may have on achieving the University’s objectives. It is an integral part of day to day operations and is an important element of effective internal control. Managers and staff at all levels are responsible for developing an understanding of and becoming competent in the implementation of risk management principles and practices in their work areas. ISO 31000 is the international standard which guides the University’s approach to risk management.
Risk Management at UWA
staff.uwa.edu.au/1936522
The University expects all those engaged in research to observe high ethical standards in the conduct of that research and, when relevant, to comply with the obligations imposed by the codes of practice as outlined by the University and other relevant funding bodies. Ethical clearances must be gained where appropriate.
UWA Code of Conduct for the Responsible Practice of Research
research.uwa.edu.au/page/73822
Australian Code for the Responsible Conduct of Research
nhmrc.gov.au/guidelines/publications/r39
Australian code for the care and use of animals for scientific purposes
nhmrc.gov.au/guidelines/publications/ea28
National Statement on Ethical Conduct in Human Research
nhmrc.gov.au/guidelines/publications/e72
National Framework of Ethical Principles in Gene Technology
ogtr.gov.au/internet/ogtr/publishing.nsf/Content/commpub-1
A conflict of interest includes any circumstance, whether actual or perceived, arising from conflict between the performance of public duty and private or personal interests. It arises where there is a reasonable expectation of direct or indirect benefit or loss for an individual employee with a particular personal interest that could be influenced in favour of that interest, in the performance of their duties. The benefit or loss may be financial or non-financial.
Staff members should take suitable measures to avoid, or appropriately deal with, any situation or relationship in which they may have, or be seen to have, a conflict of interest that could, directly or indirectly, compromise the performance of their duties. When staff members become aware of such a situation they should take appropriate steps to disclose the conflict or potential conflict. Failure to do so and continuation of such a conflict of interest will lead to disciplinary action.
The following questions may assist in identifying whether a situation or relationship is potentially a conflict of interest:
Activities that present such serious problems as to be incompatible with University policies include:
University Policy on: Conflicts of Interest
governance.uwa.edu.au/policy/UP12/32
Research Conduct
Disclosure of any potential conflict of interest is essential for the responsible conduct of research. Researchers have an obligation to disclose any affiliation with, or financial involvement in, any organisation or entity with a direct interest in the subject matter or materials of researchers. A conflict of interest may also arise if any organisation or entity with a direct interest in the subject matter provides direct benefits to the researchers such as sponsorship of the investigation, or indirect benefits such as the provision of materials or facilities, or the support of individuals such as provision of travel or accommodation expenses to attend conferences.
UWA Code of Conduct for the Responsible Practice of Research
research.uwa.edu.au/page/73822
Australian Code for the Responsible Conduct of Research
nhmrc.gov.au/guidelines/publications/r39
Professional and Personal Relationships
Examples of relationships that may cause conflicts of interest are: family relationships, positive and negative emotional relationships (including all sexual relationships, antagonisms, close friendships), and financial relationships, including sponsorships.
University Statement on: Professional Relationships in the Workplace
hr.uwa.edu.au/2202722
Employment of Close Relatives
The employment of relatives is only acceptable when the appointment is made in line with University policy regarding appointment of new employees. Prior approval must be sought from the Dean, or Executive Director where a staff member is required to directly supervise a relative. A member of staff should not take any direct part in the selection process for an appointment for which a family member is a candidate. The relationship to which this policy applies includes those of parent and child, siblings, wife and husband, including de-facto relationships and same sex partners.
University Policy on: Employment of Relatives and Close Friends
governance.uwa.edu.au/policy/UP07/183
Outside Employment and Private Practice
Professional and consultative work carried out by members of staff in their area of expertise may be of benefit to the University, the individual and the community, provided certain conditions are met. Professional and consultative work should be related to the work of the University and should not conflict with the interests of the University. Consulting is a privilege not a right and requires approval by the Head of School or equivalent.
University Policy on: Professional and Consultative Work
governance.uwa.edu.au/policy/UP07/204
Procurement
It is the responsibility of every staff member of the University involved in the supply of goods or services, to or for the University, to declare in writing all relevant interest that the staff member may have in any proposed transaction.
In particular, those staff who deal directly with suppliers must:
In the event of doubt or when there are perceptions of conflict, further advice should be sought from the Strategic Procurement team. (See also Gifts or Benefits and Hospitality below).
University Finance Manual, Expenditure Policy
finserv.uwa.edu.au/2189434
Conflicts of Interest in University Business
finserv.uwa.edu.au/2152805
University Purchasing Policies and Procedures
finserv.uwa.edu.au/2177807
University Policy on: Professional and Consultative Work
governance.uwa.edu.au/policy/UP07/204
Gifts or Benefits
Staff members should not solicit, encourage or accept gifts or benefits if it could be reasonably seen as an inducement to act in a particular way, or to place a staff member under an obligation that may either directly or indirectly compromise or influence them in their official capacity. In particular, University employees should indicate to the prospective givers that gifts cannot be accepted from those with whom the University has, or potentially has, commercial dealings.
Staff members who receive small gifts or tokens of appreciation may retain those items as personal property or donate them to the University. Small gifts are defined as having an estimated value of up to $100.00. A recipient of a gift in excess of an estimated $100.00 value must obtain written approval to retain the gift as personal property from a band 4a or higher officer.
As a general guide, School Managers or equivalents and above (subject to approval), may authorise expenditure on floral tributes, small gifts and other tokens of appreciation in the event of the death or serious illness of a staff member or person with an identifiable relationship with the University, work-related special occasions such as an important official visit or guest speaker at the University or the retirement of a longserving member of University staff.
University Finance Manual: Hospitality Policy
www.finserv.uwa.edu.au/2638904
Hospitality
The University recognises that the provision of hospitality can result in significant benefits to the institution through promoting its activities. The extension of hospitality by University staff in the furtherance of University objectives is therefore regarded as a legitimate professional activity. Hospitality is defined as the provision of meals or refreshments to persons who are visiting the University for business reasons, tourist activities and entertainment events which relate to the activities of the University, and light refreshments for internal meetings, conferences, workshops and seminars.
Appropriate occasions for the provision of hospitality at functions attended only by University staff include celebration of a notable achievement by a staff member or a group of staff, farewells to retiring staff, training programmes, and recognised festivals such as Christmas. Hospitality may only be authorised by Deans, Heads of School and equivalent staff with delegated authority. It is their responsibility to determine the nature and extent of hospitality provided. In all cases there is an expectation of ‘reasonableness’ which is established in the University Finance Manual.
University Finance Manual: Hospitality
Expenditure Policy
finserv.uwa.edu.au/2152805
Financial Delegations – To Authorise Hospitality
finserv.uwa.edu.au/2152908
Fringe Benefits Tax – Hospitality
finserv.uwa.edu.au/2161723
All staff must maintain and develop knowledge and understanding of their area of expertise or professional field. They should continuously seek to improve work performance with an emphasis on quality skills. All staff should actively seek out ways to bring about improvements in their workplaces. Students should endeavour to take full value of their learning opportunities while at The University of Western Australia
Staff Professional Development
hr.uwa.edu.au/2220096
Staff Development Grants and Awards
hr.uwa.edu.au/2190414
Leave for Professional Development and Study
hr.uwa.edu.au/2243953
University Policy on: Reimbursement of Student Contribution Amount
governance.uwa.edu.au/policy/UP07/246
University Policy on: Graduate Research Training
governance.uwa.edu.au/policy/UP12/11
For the annual Calendar of Staff Development Programs and Workshops, see:
hr.uwa.edu.au/2179879