Internal Audit But Everybody Knew!!! Cathy Blunt Manager Internal Audit.

Internal Audit

But Everybody Knew!!!

Cathy BluntManager Internal Audit

Introduction

Definitions

Policies & Procedures

Risks Associated with COI

Managing COI Risks

ExamplesInternal Audit

Internal Audit

Poor horsey is hurt!!



Ouch!

Internal Audit

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 para10).

Internal Audit


Perceived - where a

reasonable person might

perceive that such improper

influence could exist.

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.


Internal Audit

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.

University Policies & Procedures

Risk & Fraud ManagementRisk Management Policy & FrameworkCode of ConductGifts and Benefits PolicyFraud Control Policy and Fraud Control ProcedureConflict of Interest Policy & Disclosure StatementPublic Interest Disclosure PolicyPhilanthropy and Fundraising Policy

HR Management Academic and General Staff Misconduct Committee Guidelines Academic & General Staff AgreementsPreserving Professional Relationships GuidelinesIndividual Grievance Resolution ProcedureRecruitment and Selection Procedures Private Practice Policy

Internal Audit

University Policies & Procedures

ResearchGuide to Responsible Conduct of Commercialisation ActivitiesConsultancy and Commercial Research PolicyGriffith University Code for the Responsible Conduct of Research Griffith University Human Research Ethics ManualIntellectual Property Policy

Qld Government LegislationFinancial Accountability Act 2009Crime and Misconduct Act 2001Public Sector Ethics Act 1994

Internal Audit

Risks1. 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 & proceduresTone at the Top – Live the PoliciesEncourage open communication about issuesEstablish processes to disclose and manage COI, e.g. staff meetingsSupervision Be aware of changes to processes and systems that may create opportunitiesEncourage staff to report issuesEnsure 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 possibleAssist with any investigationIf an incident occurs, consider staff awareness trainingReview controls in place and improve if necessary

Internal Audit

The Fun Bit - Examples

Internal Audit

The Griffith School of International Government Relations & Business has received AusAid 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

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 AusAid.

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 “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

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

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

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

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 But Everybody Knew!!! Cathy Blunt Manager Internal Audit.

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