Corruption Risk Control


The Fraud and Corruption Prevention Policy is available online.


All public institutions have public interest obligations to take whatever steps they can to prevent corrupt conduct.

Corruption prevention is about the actions that an organisation can take to minimise opportunities for corrupt conduct to occur.

Southern Cross University's corruption prevention strategy is a component of the University's overall approach to enterprise-wide risk management.

What is corruption?

Corrupt conduct is defined in the Independent Commission Against Corruption Act 1988 (ICAC Act) as being "any conduct that adversely affects(or that could adversely affect) either directly or indirectly the honest or impartial exercise of public official functions."

Broadly, it is conduct that involves a:

  • dishonest exercise of public functions, or
  • breach of public trust, or
  • misuse of information or material acquired in the course of official functions.

In addition, for the ICAC to exercise its jurisdiction over a matter, the conduct must be such that, if proved, it could constitute:

  • a criminal offence, or
  • a disciplinary offence, or
  • reasonable grounds for dismissing, dispensing with the services of or otherwise terminating the services of a public official.

It is the intention under the ICAC Act to capture only intentional or deliberate acts of corruption. Mistakes or negligence may not be considered to be corrupt because they are not done intentionally.

Why control corruption?

NSW universities are 'public authorities' as defined in section 3 of the ICAC Act and, as such, fall within the jurisdiction of the ICAC, an independent statutory body with responsibility to expose and minimise corruption in the NSW public sector.

The ICAC can, therefore, investigate allegations or complaints of corrupt conduct concerning the University or its staff (full-time, part-time, casual or contract) who are deemed to be public officials as defined in the Act. NSW universities also have statutory reporting obligations under section 11 of the ICAC Act to notify the ICAC of possible corrupt conduct.

The control of corruption within the University should be an integral element of its overall risk management processes. Corruption or the perception of corrupt conduct reflects badly on the University and has the potential to damage its reputation. Scarce resources may not be allocated fairly and equitably eg. places in a course or in the awarding of a tender, and academic standards may be threatened.

In recent years, the ICAC has conducted a number of investigations into allegations relating to universities. These investigations show that universities are subject to the same kinds of risks and vulnerabilities as other organisations that administer public funds and authority - recruitment of staff, procurement of goods and services, the use (or misuse) of public resources, and regulatory functions, for example. Further information is available on the ICAC Investigations webpage.