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Category Finance
Type Policy
Approved by VCAG, 31 January 2011
Date Policy Took Effect 31 January 2011
Last approved revision 30 November 2020
Sponsor Chief Operating Officer
Responsible officer Head of Risk, Assurance and Compliance

Purpose

Fraud damages the reputation of the University and depletes the University’s resources. Accordingly, the University has a zero tolerance to Fraud, whether by staff or other persons.

The purpose of this policy is to actively discourage fraudulent behaviour at the University of Otago and achieve a just and coordinated response to Fraud.

Organisational scope

This policy shall apply to:

  • all employees of the University,
  • all contractors to the University, and
  • all persons with honorary or unpaid staff status at the University.

Definitions

Fraud

For the purposes of this policy, “Fraud” includes all acts of deception, misrepresentation or omission committed with the intention of gaining an unjust or illegal financial or non-financial advantage, whether for oneself or a third party.

Such behaviour includes, but is not limited to:

  • Wrongful or criminal deception intended to result in financial or personal benefit.
  • Deliberately not recording leave taken.
  • Theft or unauthorised use of facilities or equipment for personal gain.
  • Inappropriate claims for expenses for personal gain.
  • Use of the University’s credit card for personal gain.
  • Inappropriate payments to third parties.
  • Corruption, i.e., the abuse of a position of trust for dishonest gain.
  • Secret commissions, kickbacks, bribes, and other forms of unlawful payments.
  • Coercion or otherwise holding assets for ransom.
  • Money laundering.

Content

1. Commitment to Controlling Fraud

  1. The University of Otago will not tolerate any fraudulent or corrupt behaviour and will investigate all instances of suspected Fraud.
  2. The University will undertake regular Fraud risk assessments and undertake reviews of transactions, activities, or locations as a result of those assessments.
  3. Should an investigation provide sufficient evidence to suggest that Fraud has been committed, the University may refer the circumstances to the relevant authorities for the purposes of further investigation and possible prosecution.

2. Requirements of University Staff

  1. Staff must report all instances of suspected Fraud to at least one of the following:
    1. the Office of Risk Assurance and Compliance,
    2. the Vice-Chancellor,
    3. the Chief Operating Officer,
    4. the Chief Financial Officer,
    5. the Director of Human Resources,
    6. the fraud email address or phone number provided below, which are monitored by the Office of Risk, Assurance and Compliance.
      Email fraud@otago.ac.nz
      Mob +64 27 4 359 808
  2. Where a notification involves (or may reasonably be regarded as having the potential to involve) one or more of the people listed under Clause 2(a) they shall be excluded from the notification.
  3. No person is to investigate a fraud unless authorised to do under Clause 4 of this policy.

3. Notifications

  1. Notifications can be written or verbal.
  2. A written record will be made of any verbal notification.
  3. The notification shall be recorded in the University Fraud Register which is maintained by The Office of Risk, Assurance, and Compliance.
  4. Notifications must be made to the persons named in clause 2(a).
  5. The persons named in 2(a) shall be Delegates of the Disclosure Officer under the Protected Disclosures Policy and Procedures.
  6. The person making a notification can request that their identity and any details which may identify them, shall be confidential to the extent provided for under the Protected Disclosures Policy and Procedures.

4. Investigations

  1. Notifications will be investigated to the fullest practical extent.
  2. The Director of Human Resources, in consultation with the persons advised of a notification under clause 2, shall determine the person responsible for conducting an investigation.
  3. Where it has been determined that the Director of Human Resources should not be advised of the notification, the Vice-Chancellor shall have responsibility for determining who should conduct the investigation.
  4. Where the Director of Human Resources is not responsible for the conduct of an investigation, the party conducting the investigation must ensure that appropriate employment processes are observed.
  5. The Office of Risk, Assurance, and Compliance shall provide updates throughout an investigation to the Chief Operating Officer, the Chief Financial Officer, and the Director of Human Resources unless a notification involves (or may reasonably be regarded as having the potential to involve) one or more of, those persons.
  6. The investigation process may include a preliminary investigation, the purpose of which shall be to determine whether a more comprehensive investigative process should be followed.

5. Confidentiality

  1. Subject to the requirements of the investigation or any legal requirements, everyone involved in a formal investigation or informal process has:
    1. The right to have information they disclose kept confidential.
    2. The duty to respect the rights of others to the maintenance of confidence.
    3. The right to have any limits of confidentiality explained to them.

6. Reporting

  1. The person with responsibility for the conduct of an investigation into a notification of fraud or corruption will prepare a report which contains:
    1. A report of the findings of the investigation and action (including employment action) taken in relation to it.
    2. A recommendation as to whether the matter was, or should be, referred to an external agency.
    3. Recommendations as to improvement in controls and processes that need to be implemented in order to minimise future recurrences of the behaviour identified by the complaint.
  2. Reports of investigations prepared under this procedure will be sent to the Vice-Chancellor as soon as is practicable following their completion and to the Audit and Risk Committee of the University Council at its next scheduled meeting.

7. Recoveries

  1. The University will pursue the recovery of monies and property lost as a result of fraud wherever practical and appropriate.

Related policies, procedures and forms

Contact for further information

If you have any queries regarding the content of this policy or need further clarification, contact:

Mark Cartwright
Head of Risk Assurance and Compliance
Email mark.cartwright@otago.ac.nz