Foreign engagements

UOW is a truly global university. Our international focus is strengthened through a collaborative network of partners across the globe. We value our collaborations with foreign partners and recognise the significance of relationships between individuals in Australia and overseas.

In the day-to-day pursuit of University objectives, there are some integrity/accountability obligations that may be more difficult to recognise and require additional vigilance by individuals to ensure compliance. Being aware of these obligations will help you identify and manage the risks and avoid adverse consequences.

The Australian government has in place a number of legislative instruments designed to ensure engagements and interactions with foreign entities or individuals do not adversely affect Australia's foreign relations and are consistent with Australia's foreign policy.

It is important to note that the vast majority of foreign engagements are not considered as notifiable or reportable to the Australian government and are out of scope for the various Schemes. Staff should also note that notification or reporting of Foreign Engagements to the Australian government will be completed as matter of legislative compliance. This does not necessarily mean that engagements will be terminated or rejected by the government.

Foreign engagements quick guide

Please note: this resource is intended as a guide and should be read in conjunction with Australian government information.

	Foreign Arrangements Scheme	Foreign Influence Transparency Scheme	Foreign Interference Guidelines
Concerning	Public disclosure of activities		Risk reduction
Purpose To ensure international activities...	Don’t adversely affect Australia’s foreign relations and are consistent with our foreign policy	That aim to influence Australian political and government decision makers are open and transparent	are free from foreign interference
Procedure	Notification	Registration	Risk management
Impact on the University	UOW must notify the Government of international arrangements with foreign governments and their entities Arrangements in scope are recorded on the Foreign Arrangements Scheme Public Register	Individuals/units must register with the Government if they are carrying out activities and communications on behalf of a foreign principal (ie a government entity or political organisation). Details are recorded on the Foreign Influence Transparency Scheme Public Register	University must ensure its practices (especially in governance, due diligence, communication, knowledge sharing and cyber security) are in line with Guidelines from the Department of Education, Skills and Employment.
What staff need to do	Be aware of which arrangements need to be notified. The university is required to notify an arrangement with a foreign government or foreign university that does not have institutional autonomy. Refer to DFAT - Fact Sheet 4 - Australian Universities for further guidance. Staff should submit a Foreign Arrangements Notification Form to notify Global Partnerships of relevant arrangements. Global Partnerships will then lodge the arrangement on behalf of the University.	Register under the scheme if they are conducting activities in Australia on behalf of a foreign principal. These activities include: parliamentary lobbying general political lobbying communications activities disbursement activity (payment of money or things of value).	Decision-makers should be aware of the Guidelines and their advice on addressing key themes and objectives.
Liability	University	Individuals and University	Individuals
Who to speak to for advice	Global Partnerships: foreign-engagements@uow.edu.au
University resources	Foreign Engagements
Legislation	Australia's Foreign Relations (State and Territory Arrangements) Act 2020	Foreign Influence Transparency Scheme Act 2018	Guidelines to Counter Foreign Interference in the Australian University Sector
Lead Government department and detailed information	Foreign Affairs and Trade Foreign Arrangement Scheme	Attorney-General Foreign Influence Transparency Scheme	Department of Education University Foreign Interference Taskforce

The below links provide an overview of each scheme including FAQs, links to Government resources and fact sheets as well as who to contact for more information.

The contents of this website will continue to be updated as refined information is received from the Australian Government.

Foreign Arrangements Scheme
Foreign Influence Transparency Scheme
Foreign Interference
Defence Export Controls
Sanctions
Security of Critical Infrastructure
Safeguarding Australia's Military Secrets

Ensures written arrangements between State/Territory entities and foreign governments and their entities do not adversely affect Australia's foreign relations and are consistent with Australia's foreign policy.

Please note: As the Schemes progress, the contents of this website will continue to be updated as refined information is received from the Australian Government.

Foreign Arrangements Scheme

Applies to Australian or foreign individuals and entities who undertake registrable activities on behalf of a foreign principal.

Foreign Influence Transparency Scheme

The Australian Government and the higher education sector jointly formed the University Foreign Interference Taskforce (UFIT). In November 2019, the taskforce released Guidelines to Counter Foreign Interference in the Australian University Sector to enhance safeguards against the risk of foreign interference. A revised version of the Guidelines was released in November 2021.

The revised Guidelines place an obligation on universities to require disclosures from staff who are at risk of foreign interference.

FOREIGN INTERFERENCE

Applies to anyone exporting regulated defence goods/technologies from Australia or transferring information from Australia.

Defence Export Controls

Sanctions address situations of international concern by restricting the trade of goods, services or commercial activities (including training), preventing travel and/or may involve financial restrictions such as the freezing of assets. They can apply to an entire country/regime, an entity or individual or be thematic.

In Australia, sanctions compliance and permits are managed by the Australian Sanctions Office (ASO).

Sanctions

The Security of Critical Infrastructure Act 2018 (SOCI Act) is designed to protect critical assets. It requires UOW to maintain information on what assets are held and report incidents promptly. Individuals need to determine if their research is deemed critical under the SOCI Act and provide this information to UOW.

SOCI - Knowledge Base Article

Closely aligned with Defence Export Controls, Safeguarding Australia's Military Secrets (SAMS) legislation regulates individuals with sensitive Defence information and experience, from training or working for military organisations and foreign government bodies without appropriate authorisation. Individuals require a Foreign Work Authorisation (FWA).

SAMS legislation

International Collaborations at UOW

International Collaborations at UOW The Australian Code for the Responsible Conduct of Research identifies broad principles that

characterise a responsible research culture. This includes outlining that those involved in research have a responsibility to disclose and manage actual, potential and perceived conflicts of interests and to also be accountable for compliance with the relevant laws, regulations, disciplinary standards, policies and guidelines to ensure proper approvals are obtained and adhered to. There is legislation that can require permits or notification to government departments before an international collaboration can proceed. It is important to understand the Acts, regulations and schemes that are designed to ensure research can proceed with transparency whilst also protecting national security and interests. Five of the legislative elements are a. The Autonomous Sanctions Act b. The Defence Trade Controls Act c. The Foreign Arrangements Scheme d. Foreign Influence Transparency Scheme and e. The Guidelines to Counter Foreign Interference in the Australian University Sector. Sanctions laws restrict trade and commercial activity and could impact your ability to recruit HDR candidates, invite visiting students and academics to the university, travel internationally or to collaborate with researchers overseas. Sanctions apply to both individuals on the consolidated list and specified countries or regimes as listed by the United Nations Security Council and Australian autonomous sanctions. A permit provides authorisation to undertake an activity that would otherwise be prohibited. Researchers are required take reasonable precautions and exercise due diligence to prevent a sanctions breach. The Defence Trade Controls Act controls the export and supply of goods, information, materials, technology with potential dual-use as outlined in the Defence and Strategic Goods List (DSGL). It applies to both physical export and digital supply such as via email. Before exporting or supplying research and data you need to assess whether a permit from the Department of Defence may be required. The Foreign Arrangements Scheme establishes a formal notification process for written agreements, contracts and understandings between the University and a foreign government and their entities. The University must notify the government that it proposes to enter one, and again when the agreement is executed. Before entering ANY agreement with international parties ensure Global Strategy has assessed the arrangement, if it needs to be notified. There are some relationships that the Australian Government requires you to declare. Examples include relationships with people involving parliamentary lobbying, general political lobbying and communication activities or payments whose purpose is political or government influence. These relationships and activities need to be registered under the Foreign Influence Transparency Scheme. Foreign interference occurs when activities are carried out by, or on behalf of a foreign actor, which are coercive, clandestine, deceptive or corrupting, and are contrary to Australia’s sovereignty, values and national interests. The Australian Government has identified the higher education sector is at particular risk of foreign interference, for example, through the compromise of valuable research or sensitive data. Universities must obtain declaration of interest disclosures from staff to identify risks of foreign interference, including identification of foreign affiliations, relationships and financial interests. At UOW we have policies, processes, guidelines, checklists and websites which provide information and advice. We also have people available to answer queries and help you understand the legislation and remain compliant. a. The Research Integrity Office has oversight of Defence Export Controls and non-HDR related sanctions. b. There are Research Integrity Advisors, experienced researchers based in your School. c. The Graduate Research School can assist with HDR recruitment involving sanctions d. For queries related to Foreign Arrangements, Foreign Influence or Foreign Interference contact the Global Strategy Division. e. There are checkpoints in grants processes f. And in commercial contracts processes with the Research Services Office who may also g. reach out to UOW’s Legal team for advice If you are a. embarking on new international research b. engaging with a new international collaborator c. exporting something with a potential dual-use in a military setting d. interacting with a person from a sanctioned regime e. believe you may have a registrable activity, or f. be at risk of foreign interference… please speak up and seek advice. Being transparent and accountable when collaborating internationally creates a safe, respectful environment, protects Australia’s national interests and contributes to a positive reputation for the research community. Contact us. Sanctions and Defence Export Controls - uow-researchintegrity@uow.edu.au Foreign Arrangements, Foreign Influence and Foreign Interference - gsd-enquires@uow.edu.au