Fri, 31 Mar 2023
Prevention and Response to Corruption Fraud and Mismanagement Policy
This policy establishes the principles, approach and responsibilities for the prevention, detection and response to corruption, fraud and mismanagement for Metavision Institute. Corruption, fraud and mismanagement are in conflict with the mission, aims, goals, values, policies and processes of Metavision Institute, and may be illegal.
Metavision Institute is committed to implementing effective risk management to ensure staff members work to a high level of integrity and prevent and detect corruption, fraud and mismanagement. Action will be taken as outlined in this policy in the case of allegations and acts of corruption, fraud and mismanagement.
This policy applies to all staff, contractors, governance board and committee members and students of Metavision Institute.
Corruption: the misuse of entrusted power in a professional role for private gain. Corruption can occur on many levels and has a negative effect on organisations and individuals by undermining trust and integrity. It impacts the integrity of service delivery and organisational and academic governance.
Fraud: the use of dishonest or deceitful means to gain an advantage. Fraud also includes the deliberate falsification, concealment, destruction or use of falsified documentation for a business purpose.
Fraud may include, but is not limited to, bribery (or the offering, giving, soliciting or acceptance of an inducement or a reward in order to improperly influence someone's actions); extortion; collusion; obstruction of justice; embezzlement; abuse of role and function; illicit enrichment; creating or exploiting conflicting interests; improper favouritism or nepotism; or the failure to disclose an interest in order to enjoy financial or other benefits or gains.
The advantage gained by fraud may include:
- An appointment or promotion to a position.
- A significant increase in professional reputation or esteem that improves future employment prospects.
- The obtaining of research or grant funding.
- Any other academic benefit that occurs following the use of the fraudulent information, credentials or qualification.
Mismanagement: poor and inadequate management and/or control of Metavision Institute’s operations. This may include substantial mismanagement of resources, substantial risk to occupational health and safety, or failure to follow and implement Metavision Institute’s mission, strategic goals, values, policies and processes. This may include failure to manage or control an approved project or program. The staff member’s alleged conduct must be serious enough to constitute reasonable grounds for disciplinary action or dismissal.
Relevant TEQSA Threshold Standards
This policy aligns with the following requirements of the Higher Education Standards Framework 2015: Standards 6.1 Corporate Governance and 6.2 Corporate Monitoring Accountability, particularly 6.2.1d: monitoring of financial position, performance, cash flows and reporting, 6.2.1e: risk identification, management and mitigation, and 6.2.1k: identification and correction of lapses in compliance with the Standards.
1. Metavision Institute’s policy approach to corruption, fraud and mismanagement is based on the following principles:
- Metavision Institute expects and encourages ethical conduct and a high level of integrity by all members of its community.
- Corrupt and fraudulent activities are unethical and illegal and will not be tolerated.
- Metavision Institute ensures that employees, contractors and governance committees are aware of their responsibilities for preventing, detecting and responding to corrupt and/or fraudulent activities and mismanagement, by establishing this policy, the Risk Management Framework, and financial and procedural controls.
- Metavision Institute fosters a culture that supports the prevention, detection and reporting of suspected fraud, corruption or improper conduct, and protects and advises individuals who report such conduct.
- All employees are required to maintain the integrity of Metavision Institute and support all efforts to prevent and detect corruption, fraud and mismanagement.
- All suspected and reported cases of alleged fraud, corruption and/or mismanagement are carefully investigated and reported to the Governance Board.
- Metavision Institute maintains confidentiality of allegations of corruption, fraud and mismanagement, and provides procedurally fair, independent and unbiased investigation processes.
- If an investigation finds that fraud, corruption and/or mismanagement have occurred, disciplinary procedures are commenced against the staff member, contractor and/or student involved.
- Confirmed illegal actions involving corruption and/or fraud by staff, contractors, directors and students will be reported to the New South Wales Police.
2. Metavision Institute aims to prevent corruption, fraud and mismanagement through the development of preventative strategies, initiatives and systems. The commitment of the Governance Board and senior management is reflected in the following strategies:
- Setting high standards of ethical and professional conduct for staff, contractors, governance board and committee members, and students of Metavision Institute,
- Inducting and training staff and contactors to understand and identify corruption, fraud and mismanagement in their areas of responsibility. Risk areas include:
- Procurement of goods and services,
- Selection, recruitment and appointment of staff,
- IT systems access, data management and IT services and supplies,
- Financial transactions,
- Payroll, and/or
- Student admission, graduations and unit result records.
- Ensuring that financial processes and reporting are subject to appropriate internal and external controls able to prevent and detect corruption and fraud in early stages.
- Implementing the Risk Management Framework and maintaining the Risk Register for identified risks, including recording actions taken and outcomes, by the Executive Committee.
3. Detection of suspected corruption, fraud and/or mismanagement by staff, contractors, governance board members and students, requires the following responses:
- Regular financial reporting to the Governance Board and annual financial audits support detection and identification of any instances of corruption or fraud.
- Any instance of suspected corruption, fraud or mismanagement is reported to the staff member’s line manager, or to the Executive Officer, as appropriate to the context. Reports may be made verbally or in writing and need to clearly explain the basis for making a report.
- On receipt of a report, the line manager informs the Executive Officer as soon as practically possible.
- The Executive Officer communicates the report to the Academic Director and Chair of the Governance Board at the earliest opportunity.
- All staff members are required to act reasonably and in good faith in reporting or responding to alleged instances of corruption, fraud or mismanagement, to maintain confidentiality, and to cooperate fully with an investigation.
4. Senior management and the Governance Board of Metavision Institute appropriately respond to and investigate reports of suspected corruption, fraud and mismanagement. The response is conducted in confidence and with due regard for all parties’ privacy.
- Metavision Institute’s Accounts Manager and independent Accountant will provide confidential advice on any reported corruption or fraud to the Governance Board.
- The Governance Board decides on further investigation and actions to be taken in response to the advice. Actions may include:
- The appointment of an independent investigator to conduct an enquiry with procedural fairness and a presumption of innocence. The investigator is to submit a written report within 30 business days to the Chair of the Governance Board,
- Disciplinary action against a staff member, which may result in change of duties, increased supervision, or suspension or termination of employment,
- A requirement to repay money and/or return assets or property,
- Reporting a crime to the New South Wales Police, or other external agency or association, and/or
- A vote of no confidence against a Director and removal from the Governance Board.
- Information about suspected and upheld reports of corruption, fraud and mismanagement is recorded in the Risk Register.
The Governance Board is responsible for corporate governance and oversight of Metavision Institute’s higher education operations, and for ensuring appropriate financial controls are in place.
The Executive Committee is responsible for ongoing risk management of the potential for corruption, fraud and mismanagement to occur, and for reporting on risk mitigation and control strategies to the Governance Board.
The Executive Officer and Accounts Manager are responsible for implementing this policy and for establishing and maintaining an effective internal control and prevention strategies.
All staff members, particularly those in management positions, are responsible for identifying and reporting suspected instances of corruption, fraud and mismanagement.
- Governance and Delegations Framework
- Risk Management Framework
- Risk Register