Ethical and Accountable Conduct - Public Interest Disclosures Policy

Document Number000969
Date Approved8 February 2012
Date Last Amended23 May 2013
                             

1.      Introduction

           The University of Newcastle is committed to upholding the highest standards of academic, personal and business integrity and to practising the values of honesty, fairness, trust, accountability and respect, as expressed in the Code of Conduct. It promotes an organisational culture that does not tolerate any act of corrupt conduct, maladministration, serious and substantial waste of public money, government information contravention or any other wrongdoing.

           The University is thus committed to the aims and objectives of the Public Interest Disclosure Act 1994 (PID Act) and strongly supports disclosure by public officials concerning any such matters.

           This policy relates to disclosures made by public officials of the University of Newcastle, and reporting of such disclosures, where the nature of those disclosures meets the requirements for consideration under the PID Act [1].

2.      Policy Scope

           This Policy applies to all University staff, conjoint appointees, volunteers, and members of advisory and governing bodies, in all campuses and locations of the University and at all times while engaged in University business or otherwise representing the University.

           The scope encompasses affiliates, contractors and consultants, appointed or engaged by the University to perform duties or functions and/or recognised for their contribution to the University.

          This policy will also be applied by the University to disclosures made by staff in relation to its controlled entities but in recognition of the requirements of the Corporations Act placed on those entities. In like manner disclosures made by students and other non employees will also be afforded protection from reprisals but it must be understood that students and non employees do not have the formal legal protection conferred under the Act.

3.      Policy Intent

           This policy establishes a system for the reporting of disclosures relating to corrupt conduct, maladministration, serious and substantial waste of public money, government information contravention or any other wrongdoing by the public officials of the University of Newcastle.

           It places responsibilities upon public officials at all levels within the University of Newcastle.  All public officials have an important role to play in supporting those who have made legitimate disclosures. They must abstain from any activity that is or could be perceived to be victimisation or harassment of any person who has made a disclosure. Further, they should protect and maintain the confidentiality of any person they know or suspect to have made disclosures [2].

4.      Definitions

 In the context of this policy:

Corrupt conduct means the dishonest or partial exercise of official functions by a public official or the conduct of a person who is not a public official, when it adversely affects the impartial or honest exercise of official functions by a public official.

Detrimental action means action causing, comprising or involving any of the following:

a) injury, damage or loss    

b) intimidation or harassment

c) discrimination, disadvantage or adverse treatment in relation to  employment

d) dismissal from, or prejudice in, employment, and

e) disciplinary proceedings

Disclosures Coordinator is the Director, Complaints and Information Management, who has the central role in the internal reporting system under this policy.

Disclosures Officer means the person(s) at the University of Newcastle who are responsible for receiving, forwarding, and/or otherwise dealing with reports under this policy (see section 7).

Fraud means an intentional act by one or more individuals among management, those charged with governance, employees, or third parties, involving the use of deception to obtain an unjust or illegal advantage. (2)

Government information contravention is a failure to properly fulfil functions under the Government Information (Public Access) Act 2009 (GIPA Act).

Maladministration means conduct that involves action or inaction of a serious nature that is contrary to law, unreasonable, unjust, oppressive or improperly discriminatory or based wholly or partly on improper motives.

Other wrongdoing means any activity or incident that appears to be wrong and should be reported.

Principal Officer means the Vice-Chancellor.

Public official(s) means an individual who is covered by the Scope of this policy.

Serious and substantial waste of public money is the uneconomical, inefficient or ineffective use of resources that could result in the loss or wastage of public resources.

Serious wrongdoing means corrupt conduct, maladministration, serious and substantial waste of public money, government information contravention or any other wrongdoing.

Reasonable grounds is whether, from an objective viewpoint, the basis for the person’s belief is reasonable. That is, would a reasonable person in the circumstances believe that wrongdoing has occurred? The belief cannot be based on personal animosity or prejudice.

5.      Policy Principles

5.5.1   What should be reported?

Public officials should report any wrongdoing they witness within the University of Newcastle. Reports about the four categories of serious wrongdoing – corrupt conduct, maladministration, serious and substantial waste of public money, and government information contravention – will be dealt with under the PID Act as public interest disclosures in accordance with this policy.

a. Corrupt conduct

Corrupt conduct is the dishonest or partial exercise of official functions by a public official. For example, this could include:

  • the improper use of knowledge, power or position for personal gain or the advantage of others
  • acting dishonestly or unfairly, or breaching public trust
  • a member of the public influencing or trying to influence a public official to use their position in a way that is dishonest, biased or breaches public trust.

For more information about corrupt conduct, see the NSW Ombudsman’s Public interest disclosures guideline on What should be reported.

b. Maladministration

Maladministration is conduct that involves action or inaction of a serious nature that is contrary to law, unreasonable, unjust, oppressive or improperly discriminatory or based wholly or partly on improper motives. For example, this could include:

  • making a decision and/or taking action that is unlawful
  • improperly exercising a delegated power

For more information about maladministration, see the NSW Ombudsman’s Public interest disclosures guideline on What should be reported.

c. Serious and substantial waste of public money

Serious and substantial waste is the uneconomical, inefficient or ineffective use of resources that could result in the loss or wastage of public resources. For example, this could include:

  • not following a competitive tendering process for a large scale contract
  • having bad or no processes in place for a system involving large amounts of public funds.

For more information about serious and substantial waste, see the NSW Ombudsman’s Public interest disclosures guideline on What should be reported.

d. Government information contravention

A government information contravention is a failure to properly fulfil functions under the Government Information (Public Access) Act 2009 (GIPA Act). For example, this could include:

  • destroying, concealing or altering records to prevent them from being released
  • knowingly making decisions that are contrary to the legislation
  • directing another person to make a decision that is contrary to the legislation.

For more information about government information contravention, see the NSW Ombudsman’s Public interest disclosures guideline on What should be reported.

e. Other wrongdoing

Although reports about the previous four categories of conduct can attract the specific protections of the PID Act, public officials should report all activities or incidents that they believe are wrong. For example, these could include:

  • harassment or unlawful discrimination
  • reprisal action against a person who has reported wrongdoing
  • practices that endanger the health or safety of public officials or the public.

These types of issues should be reported to a supervisor, in line with the University's Complaints Resolution policy  (http://www.newcastle.edu.au/policy/000745.html).

Even if these reports are not dealt with as public interest disclosures, the  University of Newcastle will consider each matter and make every attempt to protect the public official making the report from any form of reprisal.

5.5.2   What is not a public interest disclosure

Reports by public officials are not public interest disclosures and therefore not covered by the Act where they:

a)  are made with the sole or substantial motive of avoiding dismissal or other disciplinary action; or

b)  mostly involve questioning the merits of government policy.

The University encourages its public officials to raise matters of concern at any time.  Staff who have concerns about matters which they feel are inappropriate, but which do not fall within the objectives of the PID Act, can raise those concerns with their supervisors, or lodge a complaint through the University Complaints process.

5.5.3   What disclosures are protected 

The University of Newcastle will support any public official who reports wrongdoing. For a report to be considered a public interest disclosure, it has to meet all of the requirements under the PID Act.  These requirements are:

  • the person making the disclosure must honestly believe on reasonable grounds that the information shows or tends to show wrongdoing; and
  • the report must be made to the Vice-Chancellor as Principal Officer of the University, to the Disclosures Coordinator, or to a Disclosures Officer; or
  • to one of the investigating authorities nominated in the PID Act, which for the University are the ICAC, the NSW Ombudsman, the NSW Auditor General or the NSW Information Commissioner (see section 8); and
  • it is made by a public official; and
  • it is made voluntarily.

If a dispute arises as a result of a public official making a disclosure the matter will be referred to the Ombudsman who will assist in the resolution of such dispute(s). 

It is important that all public officials are aware that it is a criminal offence under the PID Act to wilfully make a false or misleading statement when reporting wrongdoing.

5.5.4   Can a report be anonymous?

There will be some situations where public officials may not want to be identified when making a report. Although these reports will still be dealt with by the University, it is best if the public officials identify themselves. This allows the person making the disclosure to be provided with any necessary protection and support, as well as feedback about the outcome of any investigation into the allegations.

It is important to realise that an anonymous disclosure may not prevent the person making the disclosure from being identified. If it is not known who made the report, it is very difficult to prevent any reprisal action.

6.      How to make a report

Public officials can report wrongdoing in writing or verbally but are encouraged to make a report in writing as this can help to avoid any confusion or misinterpretation.

If a report is made verbally, the person receiving the report must make a comprehensive record of the disclosure and ask the person making the disclosure to sign this record. The public official should keep a copy of this record.

If public officials are concerned about being seen making a report, they can ask to meet in a discreet location away from the workplace.

An on-line reporting form is also available at: http://www.newcastle.edu.au/service/risk-assurance/fraud-and-corruption/reporting-corrupt-conduct.html

7.      Roles and Responsibilities

Various University officers have responsibilities under the provision of the Act.  The accompanying Procedure and flowchart outline the process and indicate the framework for reporting protected disclosures.

 Public Officials

Public officials are encouraged to report known or suspected incidences of wrongdoing in accordance with this Policy.

All public officials have an important role to play in supporting those who have made legitimate disclosures. They must abstain from any activity that is or could be perceived to be victimisation or harassment of any person who has made a disclosure. Further, they must protect and maintain the confidentiality of any person they know or suspect to have made a disclosure.

Supervisors

Supervisors are responsible for:

  • referring public officials to a Disclosures Officer where they believe a  report to be a Public Interest Disclosure;
  • maintaining confidentiality regarding any matter reported to them, or subsequently referred to a Disclosures Officer as a Public Interest Disclosure;
  • notifying the Disclosures Coordinator, the Director, Complaints and Information Management, if they believe a public official is suffering any detrimental action as a result of disclosing wrongdoing.

Disclosures Officers

Disclosures officers are responsible for receiving, forwarding and/or otherwise dealing with reports made in accordance with this policy.

The nominated Disclosures Officers for the University are:

a)  Director, Council Services and Chancellery
    The Chancellery, CH318A Ph: (02) 4921 7316

b)  General Counsel
      The Chancellery, CH259, Ph: (02) 4921 5329

c)  Director, Human Resource Services

     The Chancellery, CH371, Ph: (02) 4921 6543

d)  Chief Operating Officer
     The Chancellery, CH304, Ph: (020 4921 7363

e)   Deputy Vice-Chancellor (Research)
      The Chancellery, CH307, Ph: (02) 4921 5441

f)   Deputy Vice-Chancellor (Academic)
     The Chancellery, CH310, Ph: (02) 4921 5114

g)  Pro Vice-Chancellor (Business and Law)
     Social Sciences Building SRS03, Ph: (02) 4921 7979

h)  Pro Vice-Chancellor (Education and Arts)
     Social Sciences Building SRS21, Ph: (02) 4921 6445

i)  Pro Vice-Chancellor (Engineering and Built Environment)
     Engineering Building EF107, Ph: (02) 4921 6025

j)   Pro Vice-Chancellor (Health and Medicine)
     Bowman Building BB2-06, Ph: (02) 4921 6378

k)   Pro Vice-Chancellor (Science and Information Technology)
     Mathematics Building V201A, Ph: (02) 4921 5906

l)  Pro Vice-Chancellor (International and Advancement)
     IDC Building 205, Ph: (02) 4985 4373

Director, Complaints and Information Management – ‘Disclosures Coordinator’

The Director, Complaints and Information Management as the Disclosures Coordinator shall:

  • receive and assess disclosures made directly by public officials;
  • receive and assess disclosures made to Disclosures Officers by public officials;
  • refer disclosures to appropriate persons within the University of Newcastle who can deal with them;
  • refer disclosures to external agencies where it is appropriate;
  • assess risk and ensure support for a public official making a report;
  • ensure a person who is the alleged subject of a report is:

a)  treated fairly and impartially;

b)  told of their rights and obligations under the University’s Policies and Procedures;

c)  kept informed during any investigation;

d)  given the opportunity to respond to any allegation made against them; and

e)  told the result of any investigation.

  • where the Principal Officer is not the subject of a report, liaise with the Pincipal Officer
  • where the Principal Officer is the subject of a report, liaise with the Chancellor

upon becoming aware of any reprisal action against a persons who has made a disclosure:

  • refer any evidence of an offence of reprisal to the Commissioner of Police or the Independent Commission Against Corruption;
  • ensure a senior and experienced member of staff, who has not been involved in dealing with the initial disclosure, will investigate the suspected reprisal;
  • give the results of that investigation to the Vice-Chancellors  for  a decision;
  • where it has been established that reprisal action is occurring against a person who has made a disclosure, take all steps possible to stop that activity and protect the public official who made the disclosure;
  • initiate appropriate disciplinary or criminal action against anyone proven to have taken or threatened any action in reprisal for making a disclosure and refer the matter by providing a brief of evidence to the Director of Public Prosectuions; and
  • inform a public official who has reported reprisal action, of the progress of any investigation and the outcome.

Vice-Chancellor – ‘Principal Officer’

The Vice-Chancellor, as the ‘Principal Officer’, shall:

  • decide if a report is a public interest disclosure;
  • determine what needs to be done next, including referral of information to other authorities;
  • decide what needs to be done to correct any problem that has been identified;
  • ensure effective and robust systems are in place to support and protect public officials who report wrongdoing;
  • refer actual or suspected corrupt conduct to the Independent Commission Against Corruption;
  • issue specific directions to help protect against reprisals, including and where applicable:
    • issue warnings to those alleged to have taken reprisal action against a public official who made a disclosure;
    • relocation of a public official who made a disclosure, or a public official who is the subject of an allegation, within the current workplace;
    • transfer of a public official who made a disclosure, or the public official who is subject of an allegation, to another position for which they are qualified;
    • granting the public official who made the disclosure, or a public official who is subject of an allegation, leave of absence during the investigation of the disclosure.

8.      Alternative avenues for disclosure

Reports may also be made to the following investigating authorities:

In limited circumstances, a report may be made to a Member of Parliament or a journalist.  The circumstances are:

  • The public official making the disclosure must have already made substantially the same disclosure through the internal reporting system or to the Vice-Chancellor or to an investigating authority in accordance with the Act; and
  • The investigating authority, public authority or officer to whom the matter was originally referred has:
    • decided not to investigate the matter;
    • decided to investigate the matter but not completed the investigation within six months of the original disclosure ; or
    • investigated the matter but not recommended any action in respect of the matter; or
    • failed to notify the person making the disclosure, within six months of the disclosure, of whether the matter is to be investigated.

Most importantly, to be protected under the Act, if a report of wrongdoing is made to a Member of Parliament or a journalist, the public official making the report must be able to prove that they have reasonable grounds for believing the disclosure is substantially true and it must also be the case that the report is substantially true.

If a public official reports wrongdoing to a person or an organisation that is not listed above, the public official will not be protected under the PID Act. This may mean that the public official will be in breach of legal obligations or University Policy by, for example, disclosing confidential information, and may face severe penalties under the PID Act.

If a public official makes a disclosure in accordance with the PID Act, they will not be subject to any liability, and no action, claim or demand can be taken against them for making the disclosure.  Public officials who make a disclosure in accordance with the Act will not have breached any confidentiality or secrecy obligations and will have the defence of absolute privilege in defamation.

9.      Feedback to / rights of public officials who report wrongdoing

The University will take measures to support and protect any public official who reports wrongdoing. The University will ensure that public officials who have reported wrongdoing, regardless of whether they have made a public interest disclosure, are provided with access to any professional support they may need as a result of the reporting process – such as stress management, counselling services, legal or career advice.

The University also has staff who will support those who report wrongdoing. They are responsible for initiating and coordinating support, particularly to those who are suffering any form of reprisal.

All supervisors must notify the Director, Complaints and Information Management if they believe a public official is suffering any detrimental action as a result of disclosing wrongdoing.

Public officials who report wrongdoing will be told what is happening in response to their report.

When public officials make a report, they will be given:

  • an acknowledgement that their disclosure has been received and a copy of this policy
  • the timeframe for when they will receive further updates
  • the name and contact details of the people who can advise them what is happening.

This information will be provided within three working days from the date the report is made.

After a decision is made about how the report will be dealt with, the public official will be given:

  • information about the action that will be taken in response to the report
  • likely timeframes for any investigation
  • information about the resources available within The University of Newcastle to handle any concerns the public official may have
  • information about external agencies and services that can be accessed for support.

This information will be provided within 10 working days from the date the report is made.

During any investigation, the public official will be given:

  • information on the ongoing nature of the investigation
  • information about the progress of the investigation and reasons for any delay
  • advice if the public officials’ identity needs to be disclosed for the purposes of investigating the matter, and an opportunity to talk about this.

At the end of any investigation, the public official will be given:

  • enough information to show that adequate and appropriate action was taken and/or is proposed to be taken in response to their disclosure and any problem that was identified
  • advice about whether they will be involved as a witness in any further matters, such as disciplinary or criminal proceedings.

10.    Support for the subject of a report

The University is committed to ensuring public officials who are the subject of a report of wrongdoing are treated fairly and reasonably. The University will ensure that public officials who are the subject of a report will be:

  • treated fairly and impartially
  • told of their rights and obligations under  the University’s policies and procedures
  • kept informed during any investigation
  • given the opportunity to respond to any allegation made against them
  • told the result of any investigation.

11.    Protection available under the Act

a.      Protection against reprisals

The PID Act provides protection for people reporting wrongdoing by imposing penalties on anyone who takes detrimental action substantially in reprisal for them making the public interest disclosure. The University extends this protection to those who assist and / or contribute to University approved investigations into allegations of wrongdoing.

The University will not tolerate any reprisal action against public officials who report or assist in investigations into wrongdoing. The criminal penalties that can be imposed include imprisonment or fines. Detrimental action is also misconduct that justifies disciplinary action. People who take detrimental action against someone who has made a disclosure can also be required to pay damages for any loss suffered by that person.

Detrimental action means action causing, comprising or involving any of the following:

  • injury, damage or loss
  • intimidation or harassment
  • discrimination, disadvantage or adverse treatment in relation to employment
  • dismissal from, or prejudice in, employment
  • disciplinary proceedings.

The University will act to protect public officials who report wrongdoing from reprisals.  Public officials who take detrimental action against a person who makes a disclosure will be subject to disciplinary action in accordance with the University’s policies, and may also face severe penalties under the Public Interest Disclosures Act 1994 (PID Act).

When a report is received, we will ensure that a thorough risk assessment is conducted. This will identify any risks to the public official who reported the wrongdoing, as well as strategies to deal with those risks.

If a public official believes that detrimental action has been or is being taken against them or someone else who has reported wrongdoing, in reprisal for making a report, they should tell their supervisor, a Disclosure Officer, the Disclosures Coordinator or the Vice-Chancellor immediately.

All supervisors and Disclosure Officers must report any suspicions that reprisal action against a public official is occurring, or any reports that reprisal action against a public officials is occurring, to the Disclosures Coordinator or the Vice-Chancellor.

If the Disclosures Coordinator or Vice-Chancellor becomes aware of reprisal action against a person who has made a disclosure, they will:

  • Refer any evidence of an offense of reprisal to the Commissioner of Police or the Independent Commission Against Corruption
  • ensure a senior and experienced member of staff, who has not been involved in dealing with the initial disclosure, will investigate the suspected reprisal
  • give the results of that investigation to the Vice-Chancellor for a decision
  • if it has been established that reprisal action is occurring against someone who has made a disclosure, take all steps possible to stop that activity and protect the public official who made the disclosure
  • take appropriate disciplinary or criminal action against anyone proven to have taken or threatened any action in reprisal for making a disclosure and refer the matter by providing a brief of evidence to the Director of Public Prosecutions.

If a public official reports reprisal action, they will be kept informed of the progress of any investigation and the outcome.

The Vice Chancellor may issue specific directions to help protect against reprisals, including and where applicable:

  • issuing warnings to those alleged to have taken reprisal action against the public official who made the disclosure
  • relocating the public official who made the disclosure or the public official who is the subject of the allegation within the current workplace
  • transferring the public official who made the disclosure or the public official who is the subject of the allegation to another position for which they are qualified
  • granting the public official who made the disclosure or the public official who is the subject of the allegation leave of absence during the investigation of the disclosure.

These directions will only be taken if the public official who made the disclosure agrees to it. The Disclosures Coordinator will make it clear to other public officials that this action was taken in consultation with the public official and with management support – and it is not a punishment.

If public officials have reported wrongdoing and feel that any reprisal action is not being dealt with effectively, they should contact the Ombudsman or the ICAC – depending on the type of wrongdoing reported.

b.      Protection against legal action

If public officials make a disclosure in accordance with the PID Act, they will not be subject to any liability, and no action, claim or demand can be taken against them for making the disclosure. Public officials who make a disclosure will not have breached any confidentiality or secrecy obligations and will have the defence of absolute privilege in defamation.

c.      Maintaining confidentiality

The University realises many public officials will want their report to remain confidential. This can help to prevent any action being taken against them, for reporting wrongdoing.

The University is committed to keeping the identity of the person making the disclosure, and the fact that they have reported wrongdoing, confidential. However there may be situations where this may not be possible or appropriate. The University will discuss with those that report at the time of making the disclosure whether it is possible to keep the report confidential.

If confidentiality cannot be maintained, the University will develop a plan to support and protect the person making the disclosure from risks of reprisal. The public official making the report will be involved in developing this plan.

If a public official reports wrongdoing, they should only discuss their report with those dealing with it. This will include the Disclosures Coordinator and the Vice Chancellor.

12.    Review

This policy will be reviewed every eighteen months. For any advice or guidance about this review, contact the NSW Ombudsman’s Public Interest Disclosures Unit.

13.    Further information

For further information and advice, members of the University community are encouraged to consult the following areas of the University:

Complaints Management Office http://www.newcastle.edu.au/service/complaints/ manages all types of complaints ranging from minor administrative matters to more serious grievances concerning unwelcome, unfair, unjust or unreasonable behaviour.

Human Resource Services http://www.newcastle.edu.au/unit/human-resource-services/ provides managers, supervisors and staff members with employment-related advice and assistance relating to a broad range of issues.

Legal Office http://www.newcastle.edu.au/unit/legal/ provides managers, supervisors and staff members with independent and objective legal advice. The legal office is committed to providing timely, cost- effective, professional services, therefore reducing litigation and minimising legal risks in the performance of the daily operations of the University.

Risk and Assurance http://www.newcastle.edu.au/service/risk-assurance/ strives to assist the University community in being an efficient, transparent, well planned and controlled organisation by facilitating the practical application of risk management concepts.

Public officials can also access advice and guidance from the University of Newcastle Disclosures Coordinator, the Deputy Vice Chancellor (Academic), in The Chancellery, Phone: (02) 4921 8633 and the NSW Ombudsman’s website (www.ombo.nsw.gov.au).

14.    Appendices

   Appendix One: Process Flowchart

15.    Essential Supporting Documents

Australian Standard on Fraud and Corruption Control

Complaints Resolution Policy - 000745

Complaints Resolution Procedure - 000898

Complaints Resolution Guideline - 000899

Conflicts of Interest Policy - 000934

Promorting a Respectful and Collaborative University: Diversity and Inclusiveness Policy - 000941

Ethical and Accountable Conduct – Public Interest Disclosures Procedure (under-development)

Government Information (Public Access) Act 2009

Internal Auditing and Assurance standards

Investigation of Allegations of Research Misconduct Guidelines - 000872

NSW Independent Commission Against Corruption (ICAC) Act

Work Health and Safety Policy - 000972

Public Interest Disclosures Act 1994 (NSW)

Public Interest Disclosures Guide
http://www.ombo.nsw.gov.au/news-and-publications/publications/fact-sheets/public-interest-disclosures

Thinking about reporting serious wrongdoing Fact Sheet
http://www.ombo.nsw.gov.au/publications/PDF/factsheets/FS_thinking_about_reporting_wrongdoing.pdf 

University of Newcastle Code of Conduct

University of Newcastle Fraud and Corruption Prevention framework

University of Newcastle Privacy Management Plan - 000258 


[1] The University acknowledges reference to the University of Western Sydney’s Public Interest (Protected) Disclosures Policy and the University of Wollongong’s Public Interest Disclosure Policy in the development of this document.

[2] International Auditing and Assurance Standards Board, (2004), International Standard on Auditing 240, ‘The Auditor’s Responsibility To Consider Fraud In An Audit Of Financial Statements’, International Federation of Accountants.

Approval AuthorityCouncil
Date Approved8 February 2012
Date Last Amended23 May 2013
Date for Review8 August 2013
Policy SponsorDirector, Complaints and Information Management
Policy OwnerDirector, Complaints and Information Management
Policy ContactDirector, Complaints and Information Management
Amendment History

Amendment to Sections 4, 7, 9, 11a, 11c and 13 replacing DVC(A) with Director, Complaints and Information Management as the Disclosures Coordinator, Deputy University Complaints Manager, Deputy University Complaints Manager, 23 May 2013.

Amended Sections 4, 7, 9, 11a and 11c replacing DVC(R) with DVC(A) as the Disclosures Coordinator effective from 1 January 2013, as approved by VC, 15 November 2012. Reinserted DVC(R) as a Disclosures Officer in Section 7. Updated web links in Sections 5, 8 and 15, Governance and Policy, 15 January 2013.

Amended Definitions and Sections 7, 9, 11a, 11c and 13 to change DVC(A&GR) to DVC(R) pending arrival of new DVC(A), approved VC 15 November 2012. Also removed DVC(R) as a Disclosures Officer in Section 7 during this arrangement, Governance and Policy 4 December 2012.

Approved by Vice-Chancellor 20 February 2012.

Council endorsed the new Ethical and Accountable Conduct - Public Interest Disclosures Policy at its meeting of 2 December, to replace the Internal Reporting Policy 000618 and the Fraud and Corruption Prevention Policy 000472 and authorised the Vice-Chancellor to approve the final version (C11:254).