Report wrongdoing

At the University, wrongdoing refers to instances when a staff member or an affiliate may be involved in corrupt conduct, serious maladministration, government information contravention, privacy contravention or serious and substantial waste of public money.

Possible examples of serious wrongdoing include:

• Corrupt conduct: Giving or accepting bribes; fraudulent invoicing; misappropriation of grant funds. 
• Serious maladministration: Systemically failing to comply with recruitment processes when hiring staff; making a decision based on an improper motive.
• Government information contravention: Destroying, concealing or altering records to avoid releasing them under a Government Information Public Access Act application. 
• Privacy contravention: Using research data for marketing purposes; sharing personal information without authority. See the Privacy Policy 2017. 
• Serious and substantial waste of public money: By-passing mandatory market testing or tender requirements when making large contractual expenditures. 

• The Public Interest Disclosures Act sets out the criteria required for a report to be a public interest disclosure. These include that the report:
• Must be made by a public official – for example, you: 
  • Are employed by the University; or 
  • Are a contractor, subcontractor, volunteer or affiliate providing services on behalf of the University; or 
  • Work for an entity that is contracted by the University to provide services on its behalf.
• Must relate to one or more types of serious wrongdoing (corrupt conduct; serious maladministration; government information contravention; privacy contravention; and/or serious and substantial waste of public money)
• Must be made to the reporter’s manager or a designated disclosure officer
• Must be based on an honest and reasonable belief.

If a report is a public interest disclosure, the Public Interest Disclosures Act provides certain protections for the reporter. More details are in the University’s Reporting Wrongdoing Policy.

Anyone who suspects wrongdoing has occurred may report it to the University.

The University will take all reasonable steps to protect the reporter's identity, provided this does not hinder any investigation. The University does not tolerate detrimental action being threatened or taken against a person involved in a report of wrongdoing.

Some reports will qualify as public interest disclosures. Public interest disclosures are entitled to specific protections under the Public Interest Disclosures Act 2022.

The University's Reporting Wrongdoing Policy provides further information. 

If you witness or become aware of one of the types of wrongdoing set out in the Policy, then you should report it to Internal Audit, one of the University’s disclosure officers or, if you are a staff member, to your manager.

Reports can be made to the University's Internal Audit team:

• By emailing internal.audit@sydney.edu.au; or
• By the online reporting form, which includes the option to submit anonymously.
  

Reports can also be made:

• To a disclosure officer, who is a nominated person responsible for acting as an additional point of contact for making reports. Disclosure officers will pass your report on to Internal Audit for assessment.
• To your manager if you are a staff member at the University. Under the Reporting Wrongdoing Policy and Public Interest Disclosures Act 2022, managers have a responsibility to treat reports of wrongdoing confidentially and refer them promptly to Internal Audit.

You may choose to make a report orally or in writing.

You may also choose to make a report anonymously or non-anonymously. Making a report anonymously may limit the University’s ability to investigate the matter effectively and will mean that you cannot be informed of the outcome of any investigation.

Reports should include:

• A short description of the conduct that constitutes the alleged wrongdoing;
• Where and when key events took place;
• Names, roles and titles of people involved; and
• How each person is involved.

We take the issue of confidentiality seriously and reports of wrongdoing are treated confidentially. The University will take all reasonable steps to protect the identity of a reporter, provided that this does not hinder any investigation.

The reporter should also take all reasonable steps to maintain the confidentiality of their report.

The University’s Reporting Wrongdoing Policy provides more details.

Your report will be referred to Internal Audit to consider whether it is a public interest disclosure under the Public Interest Disclosure Act and to determine next steps. This might involve:

• An assessment or investigation by Internal Audit.
• Referral to another area of the University such as the Human Resources, Privacy or Cyber Security teams.
  

Read more in the University’s Reporting Wrongdoing Policy.

For certain matters involving Public Interest Disclosures (PIDs), the University engages Deloitte to undertake or assist with investigations. Deloitte acts under the University’s instructions and complies with the requirements of the Reporting Wrongdoing Policy 2023 and the NSW Public Interest Disclosures Act 2022. Deloitte is subject to the confidentiality and reporting requirements set out in the Reporting Wrongdoing Policy.

If you have any questions about this arrangement, please contact internal.audit@sydney.edu.au.

The University will take all reasonable steps to protect the reporter’s identity, provided this does not hinder any investigation.

The University does not tolerate detrimental action being threatened or taken against a person involved in a report of wrongdoing. The University will take all reasonable steps to stop identified detrimental action and protect the person subjected to it.

Detrimental action does not include reasonable management action and other lawful actions.

More information is provided in the University’s Reporting Wrongdoing Policy.

Some, but not all, reports will be public interest disclosures. Public interest disclosures are entitled to specific protections under the Public Interest Disclosures Act and the University’s Reporting Wrongdoing Policy.

Anyone who manages staff or is a designated disclosure officer has an important role to play under our commitment to a culture of speaking up about wrongdoing. If you receive a report of wrongdoing, it’s critical that you treat it confidentially and refer it promptly to Internal Audit.

It is important that you do the following if you receive a report of wrongdoing or serious wrongdoing: 

• Don’t jump to conclusions. 
  
• Make a confidential formal record of the report.
• Emphasise the need for strict confidentiality – by the University and also by the reporter. 
• Give the person making the report details of the University’s welfare support contacts – see Schedule 1 of the Reporting Wrongdoing Policy. 
• Refer the report to Internal Audit as soon as possible.

Details of manager’s and disclosure officer’s roles and responsibilities are set out in the Reporting Wrongdoing Policy.

If you have any questions you can also contact Internal Audit by email internal.audit@sydney.edu.au or call the Chief Internal Audit Officer on 02 8627 4991.

The University’s designated disclosure officers are listed below.

You can make a report to any of the disclosure officers listed, not just those who work at the University site or campus where you are based.

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

• A14 Holdings Pty Ltd
• Stornaway Pty Ltd
• Suzhou Xi Su Commercial Consulting Co Ltd
• The University of Sydney Vietnam Institute Company Limited
• Westmead IVF Pty Ltd.

The disclosure officers for the University’s controlled entities are listed below.

A14 Holdings Pty Ltd

Stornaway Pty Ltd

Suzhou Xi Su Commercial Consulting Co Ltd

The University of Sydney Vietnam Institute Company Limited

Westmead IVF Pty Ltd