(1) This Policy is effective from 19 July 2022. (2) This Policy is made with respect to the following legislation which is referred to as ‘Australia’s international regulatory regime’: (3) This Policy sets out the University’s commitment to comply with its obligations under Australia’s international relations regulatory regime as set out in clause 2. (4) This Policy applies to all staff, students and where relevant, associates. (5) The University appreciates that the threat of foreign interference, foreign influence and cyber intrusion are risks to Australia’s national security as well as being a risk to its operations. (6) A proactive approach to identify and address these risks will safeguard the University’s operations and reputation, support academic freedom, demonstrate the University’s understanding of national security interests, maintain the confidence of the University’s stakeholders and ensure the University can fully leverage its education and research activities. (7) The University, as well as Australian citizens and permanent residents, have legal and moral obligations to protect and act in Australia’s national interest. Failure to protect the national interest may result in the University being in breach of its obligations; staff and students may be subject to disciplinary proceedings by the University and/or criminal proceedings by the Commonwealth Government. (8) Australia’s Foreign Relations (State and Territory Arrangements) Act 2020 requires the University to disclose all ‘Foreign Arrangements’/written commitments with defined Foreign Entities to the Department of Foreign Affairs and Trade (DFAT). (9) The Minister has the power to consider and vary or overturn any Foreign Arrangement considered not to be in the national interest. (10) Disclosure to DFAT must take place before contract signing and is managed by the Office of General Counsel (OGC). Contract sponsors (as defined by the Contracts policy) have the obligation to ensure that a potential Foreign Arrangement is reported to OGC before a contract is executed. Further information about Foreign Arrangements can be found at the Deakin University Foreign Arrangements page. (11) The Guidelines to Counter Foreign Interference in the Australian University Sector require the University to proactively manage the threat of interference from foreign governments and foreign actors to safeguard the University’s security assets and sensitive information and reputation, protect academic freedom, and the integrity and benefits of its research. They contain four areas of broad focus: (12) The Guidelines therefore have broad applicability across many different University processes – including staff recruitment and appointment, conflict of interest declarations, international collaborations and partnerships, honorary appointments, cyber security and data management, and decision making. Specific University processes embed and reflect the steps staff need to follow to address the risk of foreign interference. Further information about the UFIT Guidelines can be found at the Deakin University Foreign Arrangements page. (13) The FIT Scheme seeks to ensure that the nature and extent of foreign influence over Australian Government decision making is transparent and public. Any person seeking to influence the Australian Government and decision making on behalf of a foreign power must register with the Commonwealth Attorney General’s Department as a lobbyist. (14) The University’s objects are set out in section 5 of the Deakin University Act 2009. The University must act within its objects in the interests of the University and not in the interests of a foreign power. The University may have obligations to notify the Commonwealth Government of actors it reasonably believes may constitute a foreign influence risk. (15) The Government and Political Engagement policy sets out how the University may engage with governments and political activities. It is therefore very important that all University transactions, undertakings and contracts are assessed as being in the University’s interest as required by the Contracts policy. (16) Australia’s autonomous sanctions legislation (comprised of Autonomous Sanctions Act 2011; Charter of the United Nations Act (Cwth) 1945; Weapons of Mass Destruction (Prevention of Proliferation) Act 1995 ) prohibits the provision of training, technical advice and assistance in relation to a range of goods and services (including the supply of training and technology) to specified individuals, organisations, and countries and their citizens due to national security and foreign policy grounds. It also prohibits receiving payments from sanctioned individuals or entities. (17) The University will take reasonable steps to ensure that the University and its staff, students and its associates do not, without a permit from the Minister for Foreign Affairs, undertake sanctioned activities set out in the DFAT Sanctions Regimes listings that would constitute a sanctions offence available at the Department of Foreign Affairs and Trade sanctions regimes website, including: (18) In addition to Australia’s autonomous sanctions, the University will comply with sanctions imposed by the United Nations Security Council (UNSC) and translated into Australian law. A current list of UNSC sanctions is available at the Department of Foreign Affairs and Trade sanctions regimes website. (19) The Higher Degrees by Research (HDR) Admission, Selection and Enrolment procedure specifically addresses steps to be taken to comply with autonomous sanctions in respect of enrolling international HDR students. (20) The Defence Trade Controls Act 2012 prohibits exports listed in the Defence and Strategic Goods List (DSGL) to listed overseas destinations without a permit. The DSGL includes military items and certain commercial goods that may be repurposed for military, nuclear, chemical and biological programs. The legislation also prohibits the training of individuals from listed countries in military, nuclear and like technologies. (21) The Defence Trade Controls Procedure details how the University’s research staff and students should comply with this legislation. (22) The Security of Critical Infrastructure Act 2018 imposes compliance obligations on owners and operators of critical infrastructure. This now encompasses the higher education and research sector. A university that controls or operates a ‘critical education asset’ has obligations to notify the Home Affairs of any cyber security incident affecting a critical education asset. (23) These obligations are met by the University’s Information and Communications Technology Security policy and the Critical Incident Management policy. (24) The Decision Tree on the Deakin University Foreign Interference page is provided to assist the navigation of compliance obligations in relation to foreign interference. (25) Engagement with an international partner on behalf of the University, whether a grant application to an international funding body, proposed research collaborator, academic partner, student placement host, accepting a donation or scholarship, procurement or commercial activity, or other university collaboration, requires consideration of the risks and benefits of establishing that partnership – known as due diligence. Staff should identify the relevant policy and procedures that apply specifically to their activity and ensure that any specific requirements are complied with. (26) The purpose of due diligence is (in part) to assess whether engagement with the international partner may introduce an unacceptable risk of foreign interference into the University. (27) The first due diligence step is to fill out the Foreign Interference Checklist available on the Deakin University Foreign Interference page . If concerns about foreign interference risk are identified, staff need to escalate the concern to their line manager or appropriate senior staff member. Advice of General Counsel can be sought. (28) Staff who are involved in establishing relationships with international partners must consider whether they have an interest to declare under the Declaration of Interest procedure. (29) Where a contract with an international partner is anticipated, the completed Checklist must: (30) Similarly, the approver of any activity involving an international partner that does not require a contract must also review the completed Checklist. (31) Staff or associates who engage or propose to engage with foreign nationals/individuals on behalf of the University should: (32) Staff and students who deal with Sensitive Information must also consider when a Checklist should be completed and disclosed to the Responsible Officer. (33) If staff or students are concerned about how to assess a potential foreign interference risk, they may: (34) The Responsible Officers for Deakin are: (35) For the purpose of this Policy:International Relations Regulation policy
Section 1 - Preamble
Top of PageSection 2 - Purpose
Section 3 - Scope
Section 4 - Policy
Section 5 - The Regulatory Framework
Australia’s Foreign Relations (State and Territories Arrangements) Act
Universities Foreign Interference Taskforce (UFIT) Guidelines
Foreign Influence Transparency Scheme Act (FIT Scheme)
Autonomous Sanctions Regime
Defence Trade Controls
Security of Critical Infrastructure Act
Section 6 - Procedure
Responsibilities of University Members and Associates
Specific duties – International Partnerships
Specific duties – Individuals
Guidance for staff and students
Faculty/Area
Responsible Officer
All of University
University Relations Officer (Executive Vice-President Futures)
Research Portfolio
Deputy Vice-Chancellor Research and Innovation
Faculties, Institutes and Centres
Relevant Executive Deans
Resources Portfolio
Relevant Senior Managers
Futures Portfolio
Relevant Senior Managers
Academic Portfolio
Senior Deputy Vice-Chancellor Academic
Vice-Chancellor’s Portfolio
Senior Managers
Section 7 - Definitions
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