# Fraud and Corruption Control Policy Schedule 1

**Source**: https://policies.rmit.edu.au/document/view.php?id=316
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# Fraud and Corruption Control Policy Schedule 1 - Examples of Corruption, Fraud, Public Interest Disclosures and High Risk Areas

- [Fraud and Corruption](#major1)

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### Fraud and Corruption

(1)  Refer to the definitions section of the [Fraud and Corruption Control Policy](https://policies.rmit.edu.au/document/view.php?id=47) for the defintions of fraud and corruption.

#### Public Interest Disclosures

(2)  Public interest disclosures under the [Public Interest Disclosures Act 2012](https://policies.rmit.edu.au/directory/summary.php?legislation=28) are allegations of improper conduct or detrimental action by a current or former RMIT employee or Council member. These cannot be investigated by RMIT and must be reported to the Victorian [Independent Broad-based Anti-Corruption Commission (IBAC)](https://www.ibac.vic.gov.au/).

(3)  Improper conduct may be:

1. criminal offences or corrupt conduct
2. serious professional misconduct
3. dishonest performance of RMIT functions
4. intentional or reckless breach of public trust or misuse of information
5. substantial mismanagement of RMIT resources
6. substantial risk to health or safety of a person or substantial risk to the environment
7. conduct by an RMIT officer that adversely affects the honest performance of their functions
8. conduct by an RMIT officer that is intended to adversely affect the effective performance of their functions for the benefit of another person.

(4)  Detrimental action is a reprisal against someone who makes a public interest or whistleblower disclosure. It includes intimation, harassment, discrimination or disadvantaging them in relation to their employment or career.

(5)  Employees can seek advice from Central Complaints and Investigations ([investigations@rmit.edu.au](mailto:investigations@rmit.edu.au)) or the Whistleblower Coordinator ([whistleblower@rmit.edu.au](mailto:whistleblower@rmit.edu.au)) if they are uncertain about whether to disclose suspected fraud or corruption to RMIT or to an external body.

#### High risk areas

(6)  The following table lists examples of high-risk areas for fraudulent or corrupt conduct.

|  |  |
| --- | --- |
| Area | Example |
| Misuse of assets | Use of RMIT funds or resources for personal use  Unauthorised sale of RMIT assets for personal gain |
| Misuse of position | Paying or accepting kickbacks or secret commissions from or to third parties  Receiving or offering a bribe to influence a decision  Improperly using a position to gain advantage for oneself or another person |
| Travel | Unapproved travel or travelling in a fare class for which they are not eligible as per the Travel Policy  Making false claims against RMIT’s travel insurance program  Luxurious, indulgent or excessive expenditure beyond the parameters set out in the Business Expenses Policy and Schedules  Inflated or faked expense claims |
| IT and data assets and security | Unauthorised access, use, release or destruction of data for personal advantage  Sharing of usernames and passwords to unauthorised people for a fee or other benefit  Accepting bribes for admission of students or creating fraudulent transcripts for students |
| Regulatory compliance | Providing false or misleading information  Failing to provide information where there is a legal obligation to do so |
| Personnel records / confidential information / privacy | Use or disclosure of personal information for an improper purpose  Unauthorised or unlawful alteration of personal information  Appointments without merit and motivated by personal relationships |
| Salaries, wages, allowances,  reimbursements | Payments to phantom employees  Payment to an employee for tasks not performed  Reimbursement to an employee for purchasing goods or services they were not entitled to  Payment to an employee for skills they do not have |
| Contract management | Accepting bribes or kickbacks from suppliers  Negligent or deliberate mismanagement of contracts which may include non-compliance with contract schedules or rates, misrepresentation of dates, description of services or identities of contract providers  Incorrect charging for labour and material, misuse of assets or product substitution (substituting a product for one of lesser quality) |
| Tendering | Failure to comply with tender procedures  Manipulating a tender process for improper benefit or advantage  Unauthorised or improper release of pricing or other tendering information  Accepting or offering gifts and benefits contrary to the Gifts, Benefits and Hospitality Policy  Non-compliance with the Conflict of Interest Policy |
| Credit cards, EFTPOS | Making or using forged or falsified documents or signatures  Inappropriate use of RMIT credit cards, including for personal purchases |
| Purchases and accounts payable | Entering a commercial transaction where there is a conflict of interest (without complying with the Conflict of Interest Policy)  Invoice and purchase order splitting to circumvent procedures or delegation levels  Causing, assisting or enabling unauthorised or illegal transfers of funds  False documentation in support of invoices  Creation and payments made to fictitious suppliers |
| Conflicts of interest | Failing to disclose an actual, perceived or potential conflict of interest contrary to the Conflict of Interest Policy  Failing to actively manage a disclosed conflict of interest  Allowing a conflict of interest to undermine your independence  Receiving a personal benefit for assisting a person or entity to gain work or business at RMIT  Appointing a person to a position due to personal relationships or motives other than merit |