Chief Operations Officer

The purpose of this policy is to set out the commitment, responsibilities, and procedures of Eastern College Australia in relation to fraud.

This policy applies to employees, volunteers, contractors, and anyone undertaking business with Eastern College Australia.

Fraud is defined as the intentional distortion of financial procedures, statements, or other records by persons internal or external to Eastern College Australia, which is carried out to misappropriate assets or otherwise for gain at the expense of Eastern College Australia.

Fraud examples include (but are not limited to):

• Forgery or alteration of cheques, invoices, computer records and other documents
• Any theft or misappropriation of funds, securities, supplies, or any other asset
• Failure to record leave taken
• Any irregularity in the handling or reporting of money transactions, including use of credit cards
• Unauthorised use or misuse of Eastern College Australia property, equipment, materials or records
• Any computer related activity involving the alteration, destruction, forgery or manipulation of data for fraudulent purposes or misappropriation of Eastern College Australia owned software\
• Any claim for reimbursement of expenses that are not incurred for the exclusive benefit of Eastern College Australia.

Eastern College Australia is committed to protecting its reputation, revenue, expenditure, property and other assets from any attempt, whether by employees, volunteers, members of the public, contractors, or any other person conducting business with it, to gain financial or other benefits by deceit.

Eastern College Australia accepts that it is important to establish an environment in which fraud is not tolerated and in which employees are naturally reluctant to act dishonestly.  Employees and others who do business with Eastern College Australia are expected to act in accordance with its Codes of Conduct and in the spirit of its ethical standards with honesty and integrity.
All fraudulent activities, once noticed or legitimately suspected, are to be reported, investigated, and resolved in a timely and fair manner.

1     Roles and Responsibilities

1.1     The Board:

The Board has responsibility to identify and evaluate significant areas of risk in relation to fraud, and for the oversight of all fraud control activities including, in consultation with the Executive Principal and Chief Operations Officer, how to deal with actual or suspected instances of fraud.

Requests the Executive Principal through the Chief Operations Officer to:

• Prioritise and schedule fraud control improvements in all areas of Eastern College Australia operations
• Establish an ongoing fraud control monitoring and review process
• Ensure that all expenses charged to company credit cards and appearing on monthly statements are reviewed and accounted for by the staff member’s direct manager and that staff who have authorised credit card expenses declare and demonstrate that all expenses are business-related before statements are forwarded to the Chief Finance Officer for payment.
• Ensure that the fraud policy and operating procedures are communicated to employees, volunteers and contractors through induction and training
• Report to the Board on any breaches of this policy.

1.2     Board Audit & Risk Committee

• Reviewing and monitoring policies for preventing and detecting fraud,
• Reviewing fraud reports from management and auditors.

1.3        Executive Principal

The Executive Principal has primary responsibility, through the Chief Operations Officer, for the proper management of Eastern College Australia resources and the development and implementation of systems and practices to minimise the risk of fraud and will report any instances of actual or suspected fraud to the Board when they occur.

1.4     Employees

Employees have a duty to ensure that Eastern College Australia assets are safeguarded from fraud and abuse and to ensure that Eastern College Australia powers, duties and responsibilities are exercised in an open, fair and proper manner to the highest standards of probity.  Employees will accept and support all policies and measures taken to prevent, deter, detect and resolve instances or suspected instances of fraud throughout Eastern College Australia.
Employees must immediately report all incidences of suspected fraud or corruption to the Chief Operations Officer and their supervisor (except where their supervisor may be involved in the fraud or corruption event).
The Whistle-blower Policy provides alternative reporting mechanisms and protective arrangements to encourage people who work for or with Eastern College Australia to speak up about possible wrongdoing for early resolution.

1.5     External Audit

External audit has an important role in assisting office management in the prevention and detection of fraud by:

• Independently reviewing systems, procedures and controls to ensure that there are adequate safeguards to prevent, deter and detect fraud
• Through specific audits and testing of systems, identifying areas of concern
• Producing and advising on the production of rules, regulations and policies which deter fraud.

2     Reporting and Dealing with Fraud

Step 1:      When fraud is suspected to have occurred, the Chief Operations Officer, or in their absence, the Executive Principal and/or the Chair of the Board may take the following action:

• Place the matter in the hands of an appropriate third party to investigate
• Place the matter in the hands of the police
• Determine whether it is appropriate to suspend an employee from the workplace (with or without pay) whilst investigations are being conducted.

If third party or police reports verify that fraud has taken place, the employee who has perpetrated the fraud will be dismissed without the requirement on Eastern College Australia part to give due notice according to the terms of the employment agreement and applicable awards. It also may be appropriate to seek prosecution or civil action against offenders and seek to recover funds and/or assets.

Step 2:      The Executive Principal will report any unauthorised access to edit the records of any student or graduate by any employee, student, affiliated college employee, or member of the public to the police as a possible offence and seek to recover funds and/or assets.

Other Possible Actions
Other response measures to consider following an investigation of fraud may include:

• Revision and refreshment of policies to rectify deficiencies
• Maintenance of an internal investigative capability
• Review of internal controls after every confirmed incident
• Eastern College Australia insurance program
• Public reporting of incidents where the Executive Principal approves
• Media management involvement as appropriate

The policies defined within this document must be read in conjunction with the following policy and procedural documents:

ECA Risk Profile

Whistle-blower Policy