Reporting Wrongdoing

A Public Interest Disclosure (PID) is a report of serious wrongdoing made by a public official that meets the criteria under the Public Interest Disclosures Act 2022 (NSW). Fraud and corruption reports are made under the University’s Fraud and Corruption Prevention Policy. A single report can trigger both pathways — for example, a report of corrupt conduct may qualify as a PID and also require notification to ICAC.

You don’t need to determine which applies. The Disclosures Coordinator will assess your report and ensure it is handled under the correct framework.

Yes. You can submit a report without identifying yourself through the online form. However, please note that if you report anonymously, the University may have limited ability to investigate the matter, provide you with updates, or take steps to protect you from detrimental action.

Even if you choose to remain anonymous, PID Act protections still apply to your report.

Under s.11 of the Independent Commission Against Corruption Act 1988, the Vice-Chancellor is required to report suspected corrupt conduct to ICAC. If your report raises a suspicion of corrupt conduct, the Legal Office will assess whether an ICAC notification is required.

An ICAC referral does not replace the University’s internal investigation — both can proceed in parallel. ICAC prefers matters to be reported before disciplinary action is taken.

Your report is received by the Disclosures Coordinator. You will receive acknowledgement in due course (unless you reported anonymously). The Disclosures Coordinator will assess whether the report qualifies as a PID, whether it involves suspected corrupt conduct requiring an ICAC notification, and whether you are at risk of detrimental action.

You will usually be informed of the assessment outcome within 20 business days. If an investigation is warranted, you will receive progress updates at least every three months.

Yes, you can make a report if you are not sure it qualifies as wrongdoing. You are not expected to prove that wrongdoing has occurred. You only need to honestly believe, on reasonable grounds, that the information you are providing shows or tends to show serious wrongdoing.

Report what you know and the University will assess the matter. If your concern is ultimately not substantiated, you will still be protected from detrimental action.

Your report will be received by the Disclosures Coordinator (Director, Governance Services). The Disclosures Coordinator notifies the Vice-Chancellor of all reports.

Access to your report is strictly limited to those who need to know for the purposes of assessment, investigation, or risk management.

You can report wrongdoing about anyone, including senior staff. The process is the same regardless of seniority.

• If your report concerns the Disclosures Coordinator, it will be referred to the Vice-Chancellor.
• If it concerns the Vice-Chancellor, it will be referred to the Chancellor.
• You can also make a report directly to an external integrity agency such as ICAC, the NSW Ombudsman, or the Audit Office of NSW.

If your report qualifies as a voluntary Public Interest Disclosure, you are protected under the Public Interest Disclosures Act 2022 (NSW). Protections include:

• Protection from detrimental action (bullying, harassment, intimidation, dismissal) — detrimental action is a criminal offence carrying up to 5 years imprisonment
• Immunity from civil and criminal liability for making the report
• Confidentiality — the University must not disclose your identity without consent
• Right to claim compensation if you suffer detrimental action
• Right to seek a court injunction to prevent detrimental action

Your report of wrongdoing may be referred to one or more external integrity agencies, depending on the nature of the report, including:

• ICAC (Independent Commission Against Corruption)
• NSW Ombudsman
• Audit Office of NSW
• NSW Information and Privacy Commissioner

You will be notified if a referral is made.

The reporting wrongdoing process is for serious wrongdoing, including fraud, corruption, maladministration, waste, and privacy or information contraventions. Other types of concerns should be raised through appropriate channels:

• Staff grievances (interpersonal disputes, performance management concerns) — Raise under the Complaint Policy - Staff
• Student complaints (unrelated to wrongdoing) — Raise under the Complaints Policy – Students and Members of the Public

The University has entered into arrangements with its controlled entities under s81(2) of the Public Interest Disclosures Act 2022. Under these arrangements, the University exercises the controlled entities’ public interest disclosure functions on their behalf:

• Southern Cross Campus Services Ltd
• SCU Ventures Pty Limited

Reports concerning these entities can be made using the same process as for the University.