The University must comply with legislative and other requirements when engaging with foreign individuals and entities. This applies to all types of engagement, including:
Failure to do so may lead to serious consequences.
Examples of legislative requirements imposed upon the University include:
In addition to legislative requirements, international engagement must meet government, sector and public expectations. These are to protect national and research security, maintain research integrity and transparency and safeguard the University’s reputation and public trust.
We have developed processes to ensure that staff engaging with foreign nationals or entities, consider the compliance and other risks, and take appropriate action to address the compliance obligations and mitigate any identified risks.
This includes that:
Research involving Iran, Russia or the DPKR
Any research-related collaboration (including informal academic engagement) with individuals or organisations in Iran, Russia or the Democratic People’s Republic of Korea (North Korea) must not be commenced or continued unless approval is obtained by the Deputy Vice-Chancellor (Research) using this form. Requests for approval must demonstrate a compelling justification. It is not sufficient that the activity is not defence-related.
Collaboration includes, but is not limited to, co-authorship, data sharing or access to research materials, joint grant applications or research projects, hosting academic visitors, providing technical advice, editorial roles or peer review, and thesis examination.
Any collaboration approved by the Deputy Vice-Chancellor (Research) using the above form must also be reviewed through the International Compliance Review - Foreign Arrangements (ICR-FA RESEARCH) form
Formal research agreements
All research agreements with foreign individuals and entities are subject to international compliance obligations. Staff must complete an International Compliance Review - Foreign Arrangements (ICR-FA RESEARCH) form and submit the completed form for review before entering into, or continuing, an agreement or other arrangement with a foreign individual or entity.
Onshore Higher Degree by Research Students
Research staff need to be aware that the research proposals of higher degree by research (HDR) students from sanctioned countries need to be assessed to ensure that their intended HDR topics do not contravene the UNSC or Australian Autonomous sanctions. To assist in this process the University has developed a form, the International Compliance Review - Higher Degree by Research (ICR-HDR) form which outlines the possible sanctions applicable to students from sanctioned countries. It is recommended that Supervisors review this material prior to agreeing on a particular research topic with the student.
Supervisors need to ensure that they complete the International Compliance Review - Higher Degree by Research form for all HDR applicants from sanctioned countries. The Form shall be signed by the relevant Associate Dean (Research), endorsed by the relevant Executive Dean and then be sent to the Deputy Vice-Chancellor (Research) for approval.
Offshore Higher Degree by Research Students
The same sanctions that apply to onshore HDR students apply to offshore HDR students from sanctioned countries. Supervisors need to ensure that the International Compliance Review - Higher Degree by Research form is completed for all HDR applicants from sanctioned countries and approved by the relevant approvers.
International Suppliers
For international suppliers, relevant staff involved in the procurement activity or requesting the supplier setup must complete the Preliminary International Compliance Review - International Suppliers form and provide this form with any other identified documentation to compliance@ecu.edu.au for review. The form must be completed at Section D by Compliance before the new supplier form is submitted and must be attached as evidence that the ICR review process has been completed.
General (Non-Research) Agreements
All other University activities (non-research University agreements, collaborations, and other engagements) with foreign individuals and entities are also subject to international compliance obligations.
Unless they fall into one of the other categories set out below, staff must complete an International Compliance Review - Foreign Arrangements (ICR-FA OTHER) form and submit the completed form for review before entering into, or continuing, an agreement or other arrangement with a foreign individual or entity.
Staff presenting at international conferences need to be aware that the same sanctions that apply in Australia will apply to them at any international destination. In presenting staff may not provide technical advice, assistance or training to a person from a sanctioned country on any of the sanctioned themes and may not deal with any person or entity.
Staff need to consider whether their intended presentation would breach any of the UNSC or Australian Autonomous sanctions. If their presentation could be in breach of any of the sanctions, they will have to make reasonable enquiries with the organisers of the conference about who will be attending and then decide whether they should proceed with the presentation. These steps should be documented in an official ECU records file for audit purposes.
In relation to defence trade controls staff need to consider the following:
Staff travelling to sanctioned countries need to be aware of the sanctions that apply to that country and need to take the sanctions into consideration when planning their travel program. Staff should contact compliance@ecu.edu.au prior to their travel to a sanctioned country if they have any queries.
To ensure compliance with relevant international obligations the University conducts a review of all proposed appointments of foreign individuals involved in certain research activities.
This includes individuals who:
The review applies to all types of research-related appointments, including:
To initiate the review, staff must complete the International Compliance Review – Foreign Individual Appointments (ICR-FIA) form. This process supports ECU’s commitment to responsible research conduct and ensures compliance with legal obligations while protecting the University’s research integrity and reputation.
The Department of Foreign Affairs and Trade (DFAT) maintains a list of all persons and entities listed under Australian sanctions law. Those listed may be Australian citizens, foreign nationals, or residents in Australia or overseas. The list is referred to as the “Consolidated List”. The University is responsible for undertaking the due diligence checks necessary to understand whether any of the persons or entities connected with a proposed University activity are listed.
The University has developed the Consolidated List Review Form (CLRF) to assist staff in reviewing the Consolidated List. Staff must complete the “Reviewed Entity” tab of the CLRF with the names of relevant individuals and entities and then refer to the “Possible Name Matches” column of the “Consolidated List” tab to identify whether any individuals or entities the University is proposing to engage with may be included on the Consolidated List. Detailed instructions about how to complete the CLRF are included at the “Guidance Notes” tab of the CLRF.
The relevant ICR document and completed CLRF must be provided to compliance@ecu.edu.au when submitting a proposed activity for compliance review.
Foreign interference involves covertly shaping decision-making to the advantage of a foreign power. Interference is activity done in secret by, or on behalf of, a foreign actor that is deceptive, corrupting or threatening in nature and contrary to Australia’s sovereignty and interests.
Examples include:
To mitigate the risks of foreign interference staff must disclose the following personal interests to the University:
The Conflicts of Interest policy and Consultancy and Secondary Employment policy outline the processes for disclosing these matters to the University.