Objectives

This policy sets standards and provides guidance on how to control fraud and corruption.

Message from the Director

The public, our fellow employees and other people we deal with are entitled to expect each of us to act with integrity and to protect resources, information, revenues, reputation, and the public interest. Therefore, Aeromax Solutions is committed to an honest and ethical environment that minimises fraud and corruption. Fraud and corruption are incompatible with our values and present a risk to the achievement of our objectives and the provision of our services to the public. Aeromax Solutions has a zero-tolerance approach to fraud and corruption.

Scope

This policy applies to all staff, volunteers, consultants, contractors, and outsourced service providers performing work for Aeromax Solutions.

What are fraud and corruption?

Fraud refers to dishonestly obtaining a benefit, or causing a loss, by deception or other means. In broad terms, corruption is deliberate, serious wrongdoing that involves dishonest or partial conduct, a breach of public trust or the misuse of information or material. A more detailed definition is found in s 7, s 8 and s 9 of the Independent Commission Against Corruption Act 1988.

This policy applies to fraud and corruption against Aeromax Solutions as well as fraudulent or corrupt conduct by its staff.

Policy in brief

Aeromax Solutions is committed to minimising fraud and corruption in the workplace. To achieve this, Aeromax Solutions will adopt and resource a fraud and corruption control framework that aligns to better practice.

2. Policy in detail

Approach

Aeromax Solutions will adopt an agency-wide fraud and corruption control framework that is consistent with the NSW Fraud and Corruption Control Policy (Treasury Circular 18-02). In particular, it is also the policy of Aeromax Solutions to:

• as part of its framework, implement internal controls that prevent, detect and respond to fraud and corruption
• assess its fraud and corruption risks at least every two years
• ensure all staff, including contractors, are aware of relevant fraud and corruption risks and are trained to understand Aeromax Solutions’s values, codes, policies and expectations of behaviour
• report annually to the Audit and Risk Committee on the status of the fraud and corruption control framework
• treat all complaints about, and instances of, fraud and corruption seriously. Aeromax Solutions will cooperate with all relevant investigative and regulatory bodies and will take fair, proportionate disciplinary action against any employee or third party found to have engaged in fraud or corruption
• wherever practical, align to better practice advice issued by organisations such as the NSW Independent Commission Against Corruption, the NSW Ombudsman and Audit Office of NSW

Key roles and responsibilities

In addition to the responsibilities of all staff and managers set out below, the following officers and groups have key roles in relation to controlling fraud and corruption.

• Aeromax Solutions is responsible for ensuring that an agency-wide fraud and corruption control framework is in place, modelling the highest standards of ethical behaviour and ensuring compliance with all relevant legal obligations.
• The Senior Management of Aeromax Solutions is the owner of this policy and is responsible for coordinating and documenting Aeromax Solutions’s overall fraud and corruption control framework.
• The Audit and Risk Committee is responsible for giving advice to the Director about this policy and monitoring the fraud and corruption control framework.
• The chief audit executive is responsible for Compliance.
• The chief risk officer is responsible for Risk Assessment.
• Legal counsel is responsible for all Legal aspects.
• The Head of HR is responsible for all HR-related issues.

Requirements of employees and managers

In addition to complying with all integrity-related policies including the Code of Conduct and Ethics, employees are expected to cooperate with all initiatives aimed at preventing, detecting, and responding to fraud and corruption. This includes risk assessments, training and education, audits and investigations, and the design and implementation of controls.

Managers are also expected to:

• ensure all agreed controls aimed at preventing, detecting, and responding to fraud and corruption are in place
• alert the policy owner of any undocumented or emerging fraud and corruption risks
• ensure suppliers and contractors are aware of Aeromax Solutions’ policies and expectations in relation to fraud and corruption
• ensure all staff complete relevant training and are aware of fraud and corruption risks.

3. Breaches

Any breaches to Aeromax Solutions’s Code of Conduct or Business Ethics statement should be reported to the senior management in detail.

4. Further information

Further information about this policy and fraud and corruption control can be obtained by:

• contacting the policy owner on [email protected]

visiting the website of the NSW Independent Commission Against Corruption at www.icac.nsw.gov.au