*4.1
MANAGING REPUTATIONAL RISK: CURRENT AND BEST PRACTICE
PURPOSE
To provide an analysis of current and best practice regarding managing
reputational risk, including several short case studies and some early
recommendations for managing reputational risk at the University.
PREPARED BY
Vice-Chancel or
SPONSOR
Vice-Chancel or
RECOMMENDATION That Council:
1.
Note the analysis regarding reputational risk; and
2.
Task the incoming Chief Risk Officer with:
• adding ‘’Reputational Risk’ to 2025 Strategic Risk Register; and
• providing regular updates to ARMC (AFRC) on Reputational Risk.
ACTION REQUIRED
For discussion
For decision
For information
SPEAKER
The Vice-Chancellor wil speak to the paper.
CONFIDENTIALITY
Confidential
Not Confidential
GOVERNANCE / MATERIALITY
This paper was requested by Audit and Risk Management Committee in its May meeting.
RISK
This paper relates to how and why the University should consider Reputational Risk as part of its
Strategic Risk Register.
BACKGROUND The University is in the midst of a multi-year transformation, aimed to helping the University achieve
long term financial sustainability. This program of work, which has included restructuring, job loss and
fundamental shifts in the ways of working, has been substantial. Whilst some have welcomed the
opportunity to engage in cultural change, for many, this has been a period of unwanted instability. Whilst
the University has worked hard to scaffold people during this period, there remains a great deal of
community anxiety and uncertainty.
Furthermore, as has been discussed previously at Council, and flagged in various Vice Chancellor
reports, the ANU is in a protracted negative reputational cycle. This includes negative media stories
about the University, its leadership and a range of individuals and groups; increased mis- and
disinformation on social media platforms; and increased scrutiny and criticism from politicians. This
cycle is resulting in increased psycho-social harm on named individuals, entities and the broader
community. The impact is being exacerbated by the politicisation of the higher education sector and the
realities of the University’s journey towards financial sustainability. Whilst the University has faced
negative reputational cycles before, this current cycle is revealing some underlying gaps in risk
management and mitigation.
SUMMARY OF ISSUES
Broadly defined,
reputational risk is the risk arising from a negative perception of an entity which can
affect that entity’s ability to function successfully. For a university, negative perceptions might arise in a
range of quarters – students, staff, alumni, community, government, regulators, and the media, to name
a few. Impacts of such a negative perception could include enrolment numbers, research funding,
philanthropic donations, regulatory scrutiny, organisational morale, government support, and psycho-
social harm.
The University has proactively advanced discussions on enhancing community perception, through
engaged Council members, including student representatives, who contribute valuable insights into how
public perception shapes our institutional standing. Their active participation in reputational risk
dialogues demonstrates our community's shared interest in upholding the University’s strong reputation.
Managing Reputational Risk at the ANU: a current snapshot
The University’s Risk Management Policy sets out principles to create value and preserve core
operations (see Table 1). Regarding the latter, the policy makes clear the importance of “safeguarding
our brand and long-term reputation national y and globally.” In keeping with the Risk Management Policy,
the University maintains a Strategic Risk Register which is reviewed by ARMC and Council regularly,
most recently in August 2022. In the most recent Strategic Risk Register, reputational harm was not
documented as separate risk but rather is seen as an outcome of failing to manage a range of risks
(see Attachment 4.1A).
In addition to the Risk Management policy, the University has a range of policies and procedures to
help manage reputational risk proactively and to hold those accountable who seek to damage the
University reputationally. Some of the most critical include code of conduct policies and policies and
guidelines to manage conflicts of interest (see Table 1).
Table 1: a summary of relevant policies and procedures
Title plus
Brief summary
Last
Owner
additional information
URL
updated
Risk
seeks to establish and
April 2021
University
The framework
Management maintain appropriate
Secretary
safeguards ANU from
Policy
systems of risk oversight,
(to be re- reputational risks arising
management and internal
assigned to from any gaps pertaining
control for the entity.
Chief Risk to governance, finance or
Officer)
compliance.
Disclosure of To provide a framework
October
University
The Disclosure tool was
Interest
for the identification,
2022
Secretary
updated to improve ease-
Policy
disclosure, and
of-use and compliance.
management of interests
The Disclosure tool was
of ANU Representatives
updated to improve ease-
that may create risk to the
of-use and compliance.
University and its staff.
The enhanced Disclosure
This includes any interest
Tool reinforces the
external to the University
University’s commitment
to ensure the University
to strong governance.
maintains sufficient
visibility over interests that
have a potential to create
risks or conflicts of
interest.
Gift
A gift to the University is December University
Ensures transparency in
Acceptance
defined (in accordance 2019
Secretary
donor relationships and
Procedure
with ATO Taxation Ruling
imposes financial limits,
2005/13) as a transfer of
avoiding reputational
the beneficial interest in
risks from any perceived
property, in which the
improper financial or
transfer is made
personal interest
voluntarily and arises by
associated with gifts.
way of benefaction, and
from which the giver
receives no material
benefit or advantage.
Staff Code of The Code of Conduct
April 2019
Chief
Adherence to the Staff
conduct
includes a duty for all
People
Code of Conduct fosters
University representatives
Officer
a culture of integrity and
to exercise due care and
accountability, mitigating
diligence and act in good
risks associated with
faith in relation to the use
misuse of information or
of information they
position.
interact with during the
course of their
employment.
Student
The student conduct May 2020
Registrar
Effective management of
conduct
framework provides a path
student misconduct
framework – for students to disclose or
cases upholds the
Student
report
academic
University’s commitment
Code of
misconduct or harmful
to fairness and safety,
Conduct
behaviour
impacting
strengthening trust with
student life on campus. It
students and the broader
is supported by a series of
community.
policy documents relating
to misconduct:
• Responsible
Conduct of
Research Policy
and Procedure
• Sexual
Misconduct Policy
and Procedure
• Managing
misconduct,
serious
misconduct and
suspension
Procedure
Academic
Ensures compliance with
October
Chair,
Protects the rights of staff
Freedom and academic freedom and
2021
Academic
and students to pursue
Freedom of
freedom of speech
Board
critical inquiry, debate,
Speech
requirements under the
and lawful expressions,
Policy
HESA Act 2003.
in accordance with legal
provisions.
Intel ectual
Chief,
Property (IP) Governs ownership,
Research
Critical for avoiding
Policy
protection, and
October
disputes over IP theft,
commercialisation of IP
2022
and
plagiarism, or unethical
created at ANU.
Innovation
services
commercialisation.
Public
Protects whistleblowers
December University
This policy strengthens
Interest
reporting misconduct,
2023
Secretary
protections for disclosers,
Disclosure
fraud, corruption, or risks
including those relating to
(PID) Policy
to public safety.
fraud or corruption.
Individual
Defines engagement
May 2025
Chief
Ensures alignment
Contractors
terms for contractors to
People
with
Fair Work Act 2009
Policy
ensure legal/ethical
Officer
and proper engagement
standards, including by
of contractors.
engaging them as
employees, where
required.
Socially
Commits ANU to ethical
August
Chief
Ensures we adhere to
Responsible investments.
2024
Financial
sustainable investment
Investment
Officer
goals and avoid sparking
(SRI) Policy
student protests or donor
withdrawals.
Equal
Commits ANU to equal
December Chief
Ensures that equal
Opportunity
opportunity for
2022
People
opportunity principles are
Policy
employment and
Officer
embedded in al ANU
education.
processes.
Work Health Ensures safe workplaces
March
Chief
Ensures ANU remains
& Safety
for the ANU community
2024
People
compliant with self-
(WHS) Policy and covers
Officer
insurance Comcare
physical/psychological
requirements.
hazards.
Data
Addresses data integrity,
October
University
Safeguards ANU from
Governance security, and ethical use
2022
Librarian
risks associated with data
Policy
(research, operations and
breaches and leaks.
student records).
Privacy
Protects personal
May 2022
University
Ensures management of
Policy
information col ected by
Librarian
personal data and
ANU. Outlines consent,
(Privacy
information responsibly.
storage, and access
Officer)
protocols.
Advertising
Protects the University’s
August
Director,
Provides clear
Policy
name and brand from
2022
Brand and
boundaries around the
misuse.
Marketing
use of ANU brand for
marketing purposes.
International Provides a governance
August
Chief
Sets clear pathways for
Partnerships framework for
2022
Operating
engaging and conducting
Policy
international partnerships
Officer
due diligence on
and agreements.
international partners.
Over the last 7 years, the University has developed and matured a framework for dealing with Critical
Incidents involving staff and students – there is a draft Critical Incidents Policy and Procedure ready for
consultation. Managing critical incidents well is seen as an important part of mitigating reputational risk.
s47E - Public Interest Conditional Exemptions - Certain Operations of Agencies
s47E - Public Interest Conditional Exemptions - Certain Operations of Agencies
s47E - Public Interest Conditional Exemptions - Certain Operations of Agencies
COMMUNICATION
For public release
For internal release
Not for release
ATTACHMENTS
4.1.A Strategic Risk Register (2022)
4.1.B Protocol for Managing Staff Criticism in the Media
