(1) This Procedure defines University’s management of reports of serious wrongdoing (in compliance with the Public Interest Disclosures Act 2022). (2) This Procedure supports the Serious Wrongdoing Reporting Policy. (3) This Procedure applies to, and for the benefit of, all public officials in NSW, including: (4) This Procedure does not apply to: (5) The University takes reports of wrongdoing seriously: (6) All reports must be handled in accordance with the PID Act. (7) All reports of wrongdoing will be treated with confidentiality and care, even if they do not meet the criteria for protections under the PID Act. (8) Policy documents such as the Complaints Management Policy may apply to non-PID reports, other allegations or complaints. (9) If a report is made that has not met all the requirements of a voluntary PID, at the request of the reporter, the Vice-Chancellor and President may consider deeming the report to be a voluntary PID. (10) To meet the criteria of a PID, reports of wrongdoing must be made to one or more of: (11) All complaints and reports that could potentially constitute a PID are to be lodged with WBS, who will then assess and refer the matter to the Nominated Disclosure Coordinator (NDC). (12) The NDC will refer the matter to the Serious Wrongdoing Reporting Committee (SWRC) for management. The NDC will also inform the Principal Officer that a report has been received by the University. (13) If the reporter has given written consent to have their identity disclosed to the NDC, the NDC will contact the reporter to inform them of: (14) Reports to the whistleblowing Services: (15) The reporter will be provided with a unique number: (16) Upon receiving the report from the NDC, the SWRC will: (17) The reporter will be consulted prior to any risk controls being implemented. (18) The SWRC may recommend that the subject of the report be suspended during the investigation. Any such recommendation must be in writing to the Vice-Chancellor and President, and must include a report on its initial assessment and recommendations on how the report may be managed. (19) The Vice-Chancellor and President (or delegate) will report the matter to ICAC. The report must be: (20) The NDC will: (21) The Vice-Chancellor and President as Principal Officer is responsible for: (22) The Nominated Disclosure Coordinator is responsible for: (23) Disclosure Officers are responsible for: (24) Managers are responsible for: (25) All employees must: (26) Serious Wrongdoing Reporting Procedure
Section 1 - Purpose
Section 2 - Scope/Purpose
Top of PageSection 3 - Principles
Section 4 - Making a Public Interest Disclosure Report
Top of PageSection 5 - Reporting to the Whistleblowing Service
Top of PageSection 6 - Referral to the Serious Wrongdoing Reporting Committee (SWRC)
Section 7 - Management of Suspected Cases of Serious Wrongdoing:
Top of Page
Section 8 - Roles and Responsibilities
Top of PageSection 9 - Definitions
Section 10 - Attachment 1: Nominated Disclosure Officers
View Current
This is the current version of this document. You can provide feedback on this document to the document author - refer to the Status and Details on the document's navigation bar.
Word/Term
Definition (with examples if required)
Affiliate
Includes people holding University of Wollongong Honorary Awards as conferred by the University Council, including the awards of Emeritus Professor, Honorary Doctor and University Fellow; people appointed in accordance with the Appointment of Visiting and Honorary Academics Policy; and people engaged by the University as agency staff, contractors, volunteers and work experience students.
Associate
A Director; a related entity; a director or employee of a related entity.
Contractor/s
Individuals or entities who perform a task or provide a service to the University, whether or not they are bound by a written contract to do so, e.g. security, cleaners.
Corrupt conduct
Corrupt conduct, as defined in the Independent Commission Against Corruption Act 1988 (NSW) ("the ICAC Act"), is deliberate or intentional wrongdoing, not negligence or a mistake. It must involve or affect a NSW public official or public sector organisation. This includes the University of Wollongong and its related entities.
While it can take many forms, corrupt conduct occurs when:
Detrimental action
Any action causing, comprising or involving:
Discloser
A person who makes a report of known or suspected serious wrongdoing. This includes employees, contractors, consultants or any other individual performing public duties on behalf of the University. A discloser may also be commonly known as a ‘whistleblower’.
Disclosure
Any report of actual or suspected wrongdoing within the University. Note: some, but not all, disclosures are protected disclosures.
Fraud
Deliberate and premeditated activity that involves the use of deception to gain advantage and/or obtain a financial benefit to the detriment of the University.
Examples include but are not limited to:
Government information contravention
A failure to comply with the system through which people can access government information, ie. a failure to properly fulfil functions under the GIPA Act. Examples include, but are not limited to:
Investigation
An enquiry or enquiries regarding a specific matter, which can include auditing.
Maladministration
An act or omission of a serious nature that is contrary to law, unreasonable, unjust, oppressive or improperly discriminatory and based wholly or partly on improper motives. Examples include, but are not limited to:
Manager
A public official to whom the public official reports directly or indirectly, or, a public official who directly, or indirectly supervises the public official in the exercise of the public official's function.
Mandatory PID
A report about serious wrongdoing that is made by a person because they have a legal obligation to make the report, or because making that report is an ordinary aspect of their role or function at the University.
Nominated Disclosure Coordinator
A person responsible for receiving voluntary public interest disclosures on behalf of the University. For the purposes of this Policy, the Nominated Disclosure Coordinator (NDC) is the Senior Manager Complaints.
Nominated Disclosure Officer (NDO)
A person responsible for receiving public interest disclosures for the University.
Principal Officer
For the purposes of this Policy, the Principal Officer is the Vice-Chancellor and President of the University.
Protected disclosure
The terms ‘protected disclosure’ and ‘public interest disclosure’ are often used interchangeably. Current applicable legislation refers to ‘public interest disclosures’. Legislation provides protections for those making public interest disclosures, which is why the terms are often used interchangeably. Making such disclosures is also commonly referred to as ‘whistleblowing’. (See also Public Interest Disclosure)
Public Interest Disclosure
A report of serious wrongdoing that involves corrupt conduct, maladministration, serious and substantial waste of public money or government information contravention. It may be a voluntary PID, mandatory PID or witness PID, as defined in the PID Act.
Public official
Public official means a person employed in or by an agency or otherwise in the service of an agency a person having public official functions or acting in a public official capacity whose conduct or activities an integrity agency is authorised by another Act or law to investigate:
Reasonable grounds
Reasonable grounds means a set of facts or circumstances that would indicate a judgement to be believed beyond suspicion.
Report
Any disclosure of actual or suspected wrongdoing within the University. The terms report and disclosure are often used inter-changeably.
Note: some, but not all, reports/disclosures are protected disclosures.
Serious wrongdoing
Serious wrongdoing for the purposes of this Policy generally relates to wrongdoing that is so serious that it is clearly in the public interest that it be reported, for eg. corrupt conduct, fraud, maladministration, serious and substantial waste of public money. It does not refer to general misconduct that is covered by other UOW policies, for eg bullying or harassment.
Serious Wrongdoing Reporting Committee (SWRC)
Serious Wrongdoing Reporting Committee is a high-level committee that assists the Vice-Chancellor and President and Senior Manager to discharge the University’s responsibilities with regard to the management of, and response to, allegations of serious wrongdoing at UOW.
Serious and substantial waste of public money
The uneconomical, inefficient or ineffective use of resources, authorised or unauthorised, resulting in a loss or wastage of public funds or resources. Examples include, but are not limited to:
Staff
All people employed by the University including conjoint appointments, whether on continuing, permanent, fixed term, casual or cadet or traineeship basis. Any references to staff in this Policy should be understood to mean both staff and affiliates.
Voluntary PID
A report made by a person because they decided, of their own accord, to come forward and disclose what they know.
Whistleblower
A ‘whistleblower’ is commonly understood to a person who makes a disclosure about illegal or illegitimate practices, such as fraud or maladministration, within the organisation.
Witness PID
A witness PID arises where a person discloses information during an investigation of serious wrongdoing following a request for requirement of the investigator
Work-related grievance
A grievance (complaint) about any matter in relation to an employee’s engagement or former engagement, that has personal implications for the employee, for example:
Wrongdoing
See ‘Serious Wrongdoing’
Wollongong Campus
Vice-Chancellor and President (Principal Officer)
Prof John Dewar (Interim)
Chief Operating Officer and Vice-President Operations
Matt Wright (Interim)
Senior Deputy Vice-Chancellor (Innovation, Enterprise and External Relations)
Deputy Vice-Chancellor and Vice-President (Academic and Student Life)
Prof Sue Bennett (Acting)
Deputy Vice-Chancellor (Strategy and Assurance)
Prof Sean Brawley
Deputy Vice-Chancellor (Research and Sustainable Futures)
Prof David Currow
Chief Integrity Officer
Prof Trish Mundy
Director, Student Life
Theresa Hoynes
Director, Student Administration Services Division
Dr Kellie Ridges
Director, Academic Quality and Standards
Dominic Riordan
Director, Facilities Management Division
Kathleen Packer
Chief Finance Officer
Matthew Wright
Chief People and Culture Officer
Kath Coroneos (Acting)
Chief Information Digital Officer
Ray Coury
Chief Risk and Assurance Officer
Robert Oldfield
Director, Learning, Teaching and Curriculum
Leanne Cambridge
Director, Research Services Office
Sharon Martin
Director, Library Services
Margie Jantti
Faculty Executive Manager, Faculty of Arts, Social Sciences and Humanities
Katrina Gamble
Faculty Executive Manager, Faculty of Business and Law
Sue Mathews
Faculty Executive Manager, Faculty of Engineering and Information Sciences
Jancey Malins
Faculty Executive Manager, Faculty of Science, Medicine and Health
Adele McKenzie
Chancellor
Michael Still
Complaints Management Centre
Disclosure Coordinator and Senior Manager, Complaints Management Centre
Jo Braithwaite
Complex Case Officer
Samantha Constantinou
Complaints Coordinator
Alison Attenborough
Natalie Projkoski
Regional Campuses
Campus Manager, UOW Shoalhaven
Chris Hadley
Campus Manager, UOW Southern Highlands
Stephen Lowe
Campus Manager, UOW Sutherland and UOW Liverpool
Nicole Smith
Campus Manager, UOW Eurobodalla
Jaimey Facchin
Campus Manager, UOW Bega Valley
Sam Avitaia