But Everybody Knew Cathy Blunt Manager Internal Audit

But Everybody Knew!!! Cathy Blunt Manager Internal Audit

Introduction Definitions Policies & Procedures Risks Associated with COI Managing COI Risks Examples Internal Audit

Poor horsey is hurt!! Internal Audit Poor horsey is hurt!! Ouch!

Definitions – Conflict of Interest Policy Conflict of Interest A conflict of interest involves a conflict between the public duty and private interests of a public official, in which the public official has private interests which could improperly influence the performance of their official duties and responsibilities (OECD guidelines, 2003 para 10). Internal Audit

Definitions – Conflict of Interest Policy Perceived - where a reasonable person might perceive that such improper influence could exist. Internal Audit Actual - involves a real conflict between current duties and responsibilities and existing private interests. Potential - where a conflict may arise in the future between current or future duties and responsibilities and existing or future private interests.

Definitions – Conflict of Interest Policy Internal Audit

Definitions – Fraud Control Policy § Official Misconduct includes the performance of a dishonest (not impartial) act, breach of trust or misuse of information or material acquired. § Corruption is defined as behaviour that may involve fraud, theft, misuse of position or authority or other acts that are unacceptable to an organisation and which may cause loss to the organisation, its clients or the general community § Fraud is a major subset of corruption and is a deliberate, intentional and premeditated dishonest act or omission acted out for the purpose of deceiving to gain advantage from a position of trust or authority. Internal Audit

University Policies & Procedures Risk & Fraud Management § § § § Risk Management Policy & Framework Code of Conduct Gifts and Benefits Policy Fraud Control Policy and Fraud Control Procedure Conflict of Interest Policy & Disclosure Statement Public Interest Disclosure Policy Philanthropy and Fundraising Policy HR Management § § § Academic and General Staff Misconduct Committee Guidelines Academic & General Staff Agreements Preserving Professional Relationships Guidelines Individual Grievance Resolution Procedure Recruitment and Selection Procedures Private Practice Policy Internal Audit

University Policies & Procedures Research § § § Guide to Responsible Conduct of Commercialisation Activities Consultancy and Commercial Research Policy Griffith University Code for the Responsible Conduct of Research Griffith University Human Research Ethics Manual Intellectual Property Policy Qld Government Legislation § § § Financial Accountability Act 2009 Crime and Misconduct Act 2001 Public Sector Ethics Act 1994 Internal Audit

Risks 1. Reputation 2. Personal Impacts – Employment, Relationships 3. Staff Morale & Performance 4. Financial 5. Regulatory Interest 6. Distraction Internal Audit

Managing the Risks Proactive Approach §Ensure staff are familiar with policies & procedures §Tone at the Top – Live the Policies §Encourage open communication about issues §Establish processes to disclose and manage COI, e. g. staff meetings §Supervision §Be aware of changes to processes and systems that may create opportunities §Encourage staff to report issues §Ensure managers are aware of their obligations to treat complaints with discretion and sensitivity, and in a timely manner Internal Audit

Managing the Risks Reactive Approach § Know and understand the options for reporting on issues § Report on the incident as soon as possible § Assist with any investigation § If an incident occurs, consider staff awareness training § Review controls in place and improve if necessary Internal Audit

The Fun Bit - Examples The Griffith School of International Government Relations & Business has received Aus. Aid funding to develop an online course on best practice public sector governance to be developed, updated and delivered over a 5 year period in a SE Asian Country. The course includes development of training materials such booklets, sample questions and answers, assignments and examinations and videos. Due to the culture of the country involved, the videos need to be made locally to reflect local culture and business practices. The academic staff member charged with coordinating the project was a resident of the country, and has many contacts still in-country, including relatives and friends. The staff member engages an in-country consultant to design and produce the videos, based on scripts developed by the staff member. Internal Audit

The Fun Bit - Examples Working together, they agreed to source a producer, and camera and sound team from Australia to ensure the production is top quality. The actors are sourced locally through a talent agency. As educational tools, permission to film the videos must be sought from the Department of Education. A facilitation fee is paid to a high ranking official in the Department to ensure the video can be produced within the timeframes specified by Aus. Aid. The University’s Finance Department contacts Internal Audit, concerned that the project is being poorly managed and the supporting documentation for expenditure is poor or non-existent. The project management plan was found to be poorly documented and not approved by the Head of the School. Internal Audit

The Fun Bit - Examples The “producer” engaged in Australia to coordinate the video had no industry experience, and was the spouse of the academic staff member coordinating the project. A search of the business registry in the other country revealed that the talent agency being used to source the actors was jointly owned by the academic staff member and their sibling. All the actors engaged by the talent agency to participate in the videos were relatives of the academic staff member and/or the in-country consultant The facilitation fee was made to the Uncle of the academic staff member Internal Audit

The Fun Bit - Examples A PHD student has proposed a highly controversial research project about the use of hypnosis in investigating child sex abuse cases. Under the University’s policies, a proposal for the project must be submitted to the Human Ethics Research Committee for approval. The student’s academic supervisor is a very strong supporter of the project and asks for an expedited HERC review so the project can commence ASAP. The Supervisor is a member of the HERC, and advocates, to the point of harassment, all other members for project to be approved, and participates in the decision to approve the project. From conversations held, one other HERC member is aware that the supervisor knows the student, but is not aware of the extent of the relationship. Internal Audit

The Fun Bit - Examples In the HERC deliberations, the supervisor fails to reveal the following facts: • The student is her daughter; • Her daughter is currently progressing through a very messy divorce, in which the daughter has accused her former husband of abusing their children. In addition to the supervisor not advising the conflicts to the HERC, she did not advice the School or GGRS that the student she is supervising is her daughter. Internal Audit

The Fun Bit - Examples A staff member in student administration coordinates non-school leaver applications with QTAC. As a former QTAC employee, he understands the processes involved for assessing applications from non school leavers. His partner did not complete grade 12, but wants to attend the University to study social work. However, she does not want to undertake the preparatory studies needed to complete the Special Tertiary Admissions Test, opting instead for a Personal Competency Assessment. He creates records to evidence that his partner successfully completed the Griffith Educational Tertiary/University Prep Program. Internal Audit

The Fun Bit - Examples He contacts a mate working in the non-school leaver section in QTAC and asks him to review and approve his partner’s Personal Competency Assessment. He also influences an academic staff member in the School of Social Work to approve his partner’s application by offering him fishing trips on his boat. As a result of these interventions, his partner is offered a position in the Bachelor of Social Working course. Internal Audit