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 below, 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

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), under PID Act s81, the University engages Deloitte, McCullough Robertson and Ashurst to undertake or assist with investigations. Deloitte, McCullough Robertson and Ashurst act under the University’s instructions and comply with the requirements of the Reporting Wrongdoing Policy 2023 and the NSW Public Interest Disclosures Act 2022. Deloitte, McCullough Robertson and Ashurst are 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.