Finance Policy

1. Purpose

This document outlines the overarching financial management framework for the Canberra Institute of Technology (CIT).

This document refers to a number of other CIT policy and procedure documents and should be read in conjunction with these other documents.

2. Scope

This policy applies to all CIT staff who are engaged in finance related transactions.

3. Principles

3.1 General financial arrangements

3.1.1 Accounts and financial records

CIT must conduct its financial affairs including complying with statutory reporting requirements in accordance with the Financial Management Act 1996 (FMA).

Section 56(4)(f) of the FMA requires the CIT Board to ensure that "proper accounts and records are kept of the transactions and affairs" of CIT "in accordance with accounting standards".

All CIT staff have responsibility for maintaining accurate records.

This responsibility requires staff to:

• comply with the requirements of the Territory Records Act 2002, the Government Procurement Act 2001 and relevant Commonwealth taxation legislation including the Fringe Benefits Tax Act 1986, A New Tax System (Goods and Services Tax) Act 1999, Income Tax Assessment Act 1936 and the Income Tax Assessment Act 1997. CIT's taxation reporting requirements are managed by ACT Government Shared Services;
• ensure that all agreements with customers and suppliers are documented and stored appropriately;
• ensure that all documents are correctly coded and forwarded promptly to Shared Services for processing;
• advise CIT Finance of changes required to assets or liabilities (such as write offs or disposals, transfers from another agency, new lease arrangements or major contracts outstanding at 30 June, 31 December, etc.); and
• review all financial reports received and advise of any errors, omissions or required corrections.

CIT will ensure that all financial activity is recorded in the Oracle financial system in accordance with ACT Government Shared Services requirements. This system is maintained by ACT Government Shared Services.

3.1.2 Financial delegations

The CIT Board has the main accountability for CIT’s finances. The financial responsibilities confer from section 56 of the FMA as well as under Section 8 of the Canberra Institute of Technology Act 1987 (CIT Act).

CIT’s financial functions are also governed by and section 152 of the Public Sector Management Act 1994 (PSMA).  These delegations are primarily attached to positions and not individuals.

An approved Financial Delegation provides direct authority for an individual to effect a given financial transaction.

The exercise of a Financial Delegation must be undertaken with due care and diligence. Financial Delegations are designed to ensure that decisions are made with the proper authority so that there is adequate separation of duties and as applicable, an appropriate level of supervision.

Any financial decision must be made in consideration of receiving the best possible value for money along with the consideration of appropriate risk management principles. Financial decisions must also be ethical and must always be able to withstand public scrutiny.

CIT's Financial Delegations are contained within the Financial Delegations.

3.1.3 Reporting responsibility

The preparation of financial reports complements the accountability of the Chief Executive Officer to the CIT Board. This extends to assuring accountability to the respective Minister(s) and the ACT Legislative Assembly.

In conjunction with Shared Services, CIT will prepare annual financial statements in accordance with Australian Accounting Standards and the FMA and will provide them to the ACT Auditor- General for review. The financial statements and the Auditor-General opinion is to be provided to the Minister for tabling in the Legislative Assembly. CIT as a reporting entity, reports on a January to December Financial year.

Sound financial management requires continual monitoring of the performance of CIT by the Executive and all managers. CIT prepares regular internal financial reports to assist in executing financial responsibilities and reporting to various stakeholders.

3.2 Purchasing, procurement, commitment and expenditure

3.2.1 Purchasing and procurement - general

CIT has a responsibility to ensure that public funds are expended efficiently and ethically.

All CIT staff delegated with the responsibility of procuring goods, services, or works must be conversant with the ACT Government procurement policies and guidelines. The requirements also apply to disposals (for example of assets).

CIT must adhere to the procurement legislation (Government Procurement Act 2001), regulations (Government Procurement Regulation 2007) and policies as outlined in circulars issued by the ACT Government’s Procurement area and where meeting the threshold, endorsed by the Government Procurement Board.

The Government Procurement Act 2001 (section 22A), prescribes that a Territory entity must pursue value for money when undertaking a procurement activity while having regard for:

• probity and ethical behaviour;
• management of risk;
• open and effective competition;
• optimising whole of life costs; and
• anything else prescribed by regulation.

All expenses and liabilities incurred, and all payments made by CIT are to be properly authorised.  No CIT staff member may commit any CIT money or resources unless there is funding provided in CIT’s budget and they have the appropriate Delegation and prior approval(s). All CIT staff members who approve any commitment of CIT funds must appropriately record the commitment as soon as practicable after giving it.

In undertaking any procurement activity, a delegated officer must ensure that:

• value for money is achieved, including optimisation of whole-of-life costs;
• procurement is undertaken with propriety and appropriate transparency;
• those involved with the procurement comply with a high standard of integrity, probity, professional conduct and ethical behaviour;
• environmental and sustainability issues are considered;
• social issues are considered;
• the opportunity of local regional suppliers to offer the goods or services required has been maximised;
• appropriate risk management has been undertaken; and
• ethical supplier history has been considered for appropriate works or services.

These and related requirements are expanded upon and implemented through CIT's Procurement Policy and Procurement Procedures of which all CIT staff involved in any procurement activity, including disposals, are required to comply with.

3.2.2 Contractors

Engaging a contractor involves the procurement of external sources of expert labour to achieve agreed outputs, and the effective selection, engagement and management of contractors requires a professional and structured approach to ensure that best value for money outcomes are achieved.

Use of contractors should be undertaken to:

• alleviate short term staff shortages; and/or
• obtain expertise that is not readily or otherwise available within CIT.

Approval to engage a contractor should only be given if it is the most efficient and effective approach to receiving services. Internal resources and expertise must be considered first.

Engagement of contractors should be undertaken in accordance with the highest standards of probity and should be done so without actual or perceivable prejudice or favour. The ACTPS Values and Signature Behaviours and the ACTPS Code of Conduct 2013 are to be complied with at all times.

It is essential that contractors are engaged under a contract that is specific to and as necessary, tailored to the particular project or teaching/delivery.  All contracts for the engagement of contractors should include approved contract terms and conditions.

A contract must not be entered into unless funding is available to. Care needs to be exercised to not create a contract orally or by the exchange of non-contract documents or letters. Care also needs to be exercised so that contracts are not formed or amended by informal means.

The engagement of a contractor is a procurement activity and is covered under CIT's Procurement Policy and Procurement Procedures.

3.2.3 Credit cards

CIT has incorporated the use of the Corporate Credit Card (CCC) into its overall purchasing procedures.  CCC's are provided and managed by Shared Services under Whole-of-Government banking arrangements with the Westpac bank.

Credit cards are used to create efficiency in the purchasing and payment process and to allow CIT staff to perform their duties more efficiently and effectively. CCC’s may only be used for official CIT purposes and only with prior approval from a Financial Delegate. Credit card purchases are also subject to standard procurement and Financial Delegation requirements.

The holder of a CCC is responsible for all purchasing, documentation, acquittal and payment obligations related to their cards usage.

CIT Corporate Credit Card holders must keep their cards secure, both physically and virtually. Card details are to be kept confidential to minimise opportunities for fraud and should not be provided to another staff member to make purchases in person. Consideration must be given at all times to security when undertaking credit card transactions (e.g., for purchases over the internet including for overseas transactions).

These and related requirements are expanded upon and mandated through CIT’s Corporate Credit Card Policy and Corporate Credit Card Procedures of which all CIT staff are required to comply with.

3.2.4 Travel

CIT is committed to the principles and practices as outlined in the Public Sector Management Standard 2006 Part 7.1 - Travel - domestic and international as covered by Division 10.2 of the Public Sector Management Standard 2016 (refer section 113(1)(l)).

CIT staff must ensure that all official CIT travel is efficient, effective and ethical, and that official staff travel is only undertaken in order meet operational requirements.

These and related requirements are expanded upon and are implemented through CIT's Travel Policy and Travel Procedures of which all CIT staff are required to comply with.

3.2.5 Official hospitality

Official hospitality generally involves the use of public resources to provide hospitality to persons other than entity officials to facilitate the achievement of one or more of CIT's objectives. Official hospitality may include the provision of refreshments, entertainment, gifts of property, prizes or other benefits.

As a general principle, public money should not generally be used to provide hospitality however is permissible in appropriate circumstances. The number of persons attending a CIT function involving official hospitality should be restricted to those who would be able to advance the interests of CIT or where CIT would benefit from their attendance.

The nature and level of official hospitality should be relative to the role of the participants and the benefits accruing to CIT as applicable.

CIT staff must not enter into an arrangement to provide official hospitality unless such an arrangement has been authorised by a Financial Delegate. Care must be taken in ensuring the proper use of CIT funds when conducting CIT ceremonies, purchasing gifts and conducting meetings where hospitality or related expenditure is required.

These and related requirements are expanded upon and implemented through CIT's Hospitality, Meetings, CIT Ceremonies and Gifts Policy.

3.3 Revenue

3.3.1 Revenue and receipting

CIT staff must ensure that all amounts owing to CIT are brought to account in a timely manner, and subsequently collected in a reasonable time.

All revenue and receipting activities must be carried out in accordance with the CIT Revenue and Receipting Policy and recorded in Oracle via the Shared Services processing areas.

All revenue and receipting relating to student fees must be carried out through the Banner Student Information System and in accordance with the Fees Policy. Fees raised and received through Banner are automatically recorded in Oracle.

3.3.2 Contestable Funding Sources

A significant portion of CIT’s revenue is generated through competitive Government funding schemes (‘Contestable’ funding), such as through User Grants, User Choice and Skilled Capital. These activities should as a rule, be undertaken on a cost-recovery basis.

3.3.3 Commercial activities

Additional revenue may be generated through commercial activities. Care must be taken to ensure that CIT’s commercial activities are not directly subsidised by Government funding and that activity generates sufficient revenue to cover all relevant expenditure.

3.4 Assets & Insurance

3.4.1 Asset management

CIT staff must ensure that CIT's asset base is managed effectively, efficiently and within the bounds of all applicable legislation in order to achieve CIT's operational and strategic objectives. This assists CIT in maintaining its assets and safeguarding them against misuse, theft, damage and/or obsolescence. It also allows CIT to meet its financial reporting requirements with regard to assets.

The principal objective of CIT's asset management strategy is to make the most of the service potential of an asset. This applies in the phases of acquiring, using and disposing of the asset. It also applies to managing the risks and costs of the asset over its entire life.

These and related requirements are expanded upon and implemented through Management of Assets and Portable and Attractive Items Policy and Asset Management Procedures, of which all CIT staff are required to comply with.

3.4.2 Insurance

As an ACT Government Territory Authority, CIT's general insurance needs are covered by the ACT Insurance Authority (ACTIA).

CIT staff responsible for insurance matters must disclose any insurance risk and report any potential insurance claim or incident to ACTIA via CIT Corporate Services.

CIT’s Workers Compensation needs are managed by Comcare and are dealt with under the Whole-of-Government policy WHS-7/11 Managing Injury and Illness in the Workplace.  Claims for compensation lodged by CIT employees are administered by the Shared Services injury management team.

Any incident potentially involving CIT staff becoming ill or injured at work or in the course of their employment (including those incidents that did not result in injury, but which had the potential to do so) should be reported via the Whole-of-Government reporting system 'RiskMan'.

3.5 Risk, Fraud & Corruption and Conflict of Interest

3.5.1 Risk management

Risk management:

• is the responsibility of all executives, managers and employees;
• is to be integrated into all business activities and systems; and
• shall be based on the Australia/New Zealand Standard for Risk Management (AS/NZS ISO 31000:2009).

Managing risk in CIT is a key governance responsibility and comprises CIT's Strategic Business Risk Profile, Fraud Control Plan and Anti-Fraud and Corruption Profile.

All staff have the responsibility to:

• systematically identify, analyse, evaluate and treat any risk;
• maintain an awareness of risks (current and potential) that relate to their area of responsibility;
• actively support and contribute to risk management initiatives; and
• advise managers of risk issues requireing attention.

All significant business risks shall be identified, and any affected business activity should be addressed within CIT's Strategic Business Risk Profile.

3.5.2 Fraud and corruption

Fraud can be defined as taking or obtaining by deception, money or another benefit from the government when not entitled to the money or benefit or attempting to do so - this includes evading a liability to the government.

Fraud occurs when a person dishonestly obtains property or financial advantage by deception. Where a person is provided with a benefit (material or otherwise) as an incentive to make a particular decision, or where a person deliberately makes a decision that improperly confers some benefit to themselves or an associate, then fraud has occurred.  A decision made under such circumstances would not be expected to withstand public scrutiny.

Corruption occurs when an officer or employee, seeks or obtains/receives any benefit, other than his/her lawful salary and allowances on the understanding that the officer or employee will do or refrain from doing anything in the course of his/her duties or will attempt to influence any other officer or employee on behalf of any person.

Fraud and corruption against CIT or other parties will not be tolerated in any form. Staff are urged to exercise diligence, probity and the highest level of ethics in fulfilling their duties and in all dealings.

CIT is committed to the principles and practices as outlined in the Public Sector Management Standard 2006 Part 2.3 - Fraud and corruption as detailed in Division 10.2 of the Public Sector Management Standard 2016. CIT's management and staff have a responsibility to ensure that integrity risk assessments are conducted and where necessary, fraud and corruption prevention strategies are implemented.

CIT maintains an Anti-fraud and Corruption Control Plan which is regularly updated.  All staff involved in financial processing activities are to familiarise themselves with this document and are to always exercise their duties in ways that reduce risk.

CIT staff must immediately report any potential, suspected or actual fraud, corruption or abuse of office to their supervisor, College/Division Director or the Senior Executive Responsible for Business Integrity and Risk. CIT will deal with all reports promptly and with the appropriate level of discretion.

3.5.3 Conflict of interest

A conflict of interest arises when a person making a decision, or someone related to or associated with them, may benefit from a decision.

It is the policy of CIT that its employees and others authorised to act on its behalf, avoid ethical, legal, financial, or other conflicts of interest and ensure that their activities and interests do not conflict with their obligations to CIT, as consistent with its operational and strategic objectives.

The provisions of the ACTPS Code of Ethics 2010 as outlined at Section 9 of the Public Sector Management Act 1994 sets out the general standards of conduct expected of CIT employees, which includes acting in good faith, avoiding conflicts of interest and acting with propriety as reflected in CIT’s Professional Practice documents and the RED (Respect Equity and Diversity) Framework when making decisions relating to CIT matters.

All CIT staff must notify their supervisor of any actual, perceived or potential conflict of interest whether of a personal nature or through broader awareness. If a supervisor, and a staff member notifies any matter of a conflict of interest, the supervisor must ensure that any decision that is taken is transparent and will withstand public scrutiny. This may require that the staff member advising of the matter is excluded from any potential associated decision-making process.

These and related requirements are expanded upon and implemented through CIT’s Conflict of Interest and Commitment Policy.

4. Documentation

Related reference documents are as follows:

• Procurement Policy
• Corporate Credit Card Policy
• Travel Policy
• Gifts, Benefits and Hospitality Policy
• Revenue and Receipting Policy
• Fees Policy
• Assets Management Policy
• Conflict of Interest Policy
• CIT Finance Delegations
• Procurement Procedures
• Corporate Credit Card Procedures
• Travel Procedures
• Asset Management Procedures

5. Definitions

All terminology used in this policy is consistent with definitions in the CIT Definitions of Terms.

6. Policy Contact Officer

CIT Finance.

Contact CIT Student Services on (02) 6207 3188 or email infoline@cit.edu.au for further information.