Foreign Engagement Compliance Review (FECR) Registration Form

This form relates to proposed new or renewing foreign engagements of the University of Adelaide. This includes activity arranged on behalf of a University individual through a University of Adelaide contracting entity (ICS, L&R, School/Faculty/Division).


Personal declarations (for individual arrangements made personally, not through a University contracting entity) are to be made at:

Declaration of Interest (DoI) Form


The Foreign Engagement Compliance Review has now been formalised in a framework that is documented here.


The University of Adelaide must be pro-active in safeguarding its autonomy and reputation in a global context. In recent years, the Australian Government has recommended that the Australian higher education sector apply additional vigilance to all international engagements and all research involving critical technologies, citing an unprecedented scale of foreign interference they believe is intended to harm Australia’s national interests. This vigilance should be applied to all University-related activities where the activities involve critical technologies and/or engagements with foreign entities.


Types of activity


To meet Government’s recommendation, and other national and international compliance obligations, the University has established a foreign entity compliance review process for:

  • ANY proposed agreement, variation or renewal of an existing agreement between the University of Adelaide and a foreign entity (including MoUs).
  • ANY proposed multi-party agreement including a foreign entity involving the University of Adelaide in either a lead or non-lead role.
  • ANY proposal to invite an overseas based individual/entity to visit the University (refer Note 1 for exceptions).
  • ANY proposed individual staff appointment (including Honorary ones) with any foreign entity (refer Note 2 for exceptions).
  • ANY proposed individual staff "practice of a discipline" (personal consultancy) engagement with any foreign entity (refer Note 2 for exceptions).
  • ANY activities offshore with foreign entities that have been brokered by Australian companies.


Information required


In completing the form, you will be asked to provide details of the foreign engagement activity and respond to a series of questions about relevant legislative requirements. Compliance with these laws may require additional action by you and/or the University (refer Note 3 for details of compliance requirements). There are resources and assistance available to help you navigate these legal obligations.


Compliance with legal obligations is non-negotiable and significant penalties may apply to you personally, as well as the University, if they are overlooked or ignored. The proposed activity can only be endorsed if identified risks and all legal obligations can be properly managed.


The compliance assessment process


Depending on the nature of the foreign engagement activity you describe, the information you provide may be forwarded on to other people as a part of an activity endorsement process and also to your area head or supervisor. The reason for this is to ensure that any identified risks, including actual or perceived conflicts of interest, are properly managed.


You will be notified via an automated email of the outcome of the compliance assessment process.


A proposed new foreign engagement may not proceed until such time as an automated endorsement email has been received. If an engagement is declined it may not proceed.


Additional information sources

  1. University of Adelaide Integrity and Accountability webpage
  2. University of Adelaide Foreign Compliance webpage
  3. Seek advice from the University's Defence and National Security Officer by emailing dso@adelaide.edu.au.
 

Note 1: Visit exceptions NOT requiring registration using this form

Completion of a compliance assessment form is NOT required where the proposed visit to the University is:

  1. An official international delegation (e.g. one managed by External Engagement or The Chancellory).
  2. An informal or "drop-by" visit by foreign individuals already in Australia or coming to Australia only to attend a conference.
  3. Not facilitated by the University, such as by arranging travel visas and travel, or providing access to resources (such as unsupervised access to buildings and/or IT services).
 

Note 2: Co-supervision of students at a foreign institution

Co-supervision of a student at a foreign institution is exempt from FECR unless the activity crosses into the following areas of concern:

  1. International Sanctions (use this form to describe how sanctions are involved).
  2. Defence dual use technology / sensitive technology (use this form to determine the need for Defence Export Permits, etc.).
  3. You receive benefits that exceed $500 that are not administered through UoA processes. In this last instance the activity should be registered using the Declaration of Interest (Personal) form.
 

Note 3: Exceptions for foreign engagements contracted by other Australian entities

Engagement with foreign entities that are contracted through OTHER Australian entities (e.g. another university) do not need to be FECR endorsed as long as the University of Adelaide is not named or required to execute a formal agreement with or naming the foreign entities or expending resources to support the activity with the foreign entities:

  1. A grant with foreign PI/CIs submitted by another Australian university is FECR-exempt as long as the University of Adelaide participation agreement is only with the other Australian university.
  2. A visit to the University of Adelaide by a foreign PI/CI on a grant obtained by another Australian university DOES require FECR endorsement (request to host a foreign visitor).
 

Note 4: Compliance obligations to consider

The remaining text prior to the form itself describes some of the Australian and International statutes to which we must adhere.

 

Foreign Arrangements Scheme (FAS)

The Foreign Arrangements Scheme establishes a formal notification process that applies to all Australian public universities. The Scheme is established by the Australia’s Foreign Relations (State and Territory Arrangements) Act 2020 (Cth) (the Act). Public universities are included in the definition of “State/Territory entities” along with all Australian State, Territory and local governments. Under FAS all arrangements with certain "Foreign Entities" need to be registered with the Foreign Minister. A useful UoA-internal Foreign Arrangements Scheme information website is provided by Legal & Risk.

 

Foreign Influence Transparency Scheme (FITS)

The Foreign Influence Transparency Scheme applies to anyone acting on behalf of a foreign government, political party or its agents where that activity is for the primary purpose of influencing Australian political or government outcomes. A person who makes an arrangement with such a foreign entity for purpose of influencing government activity in Australia must register the relationship and the nature of the activity with the Commonwealth Attorney General’s Department. See:

  1. https://www.ag.gov.au/Integrity/foreign-influence-transparency-scheme/Pages/default.aspx
  2. https://transparency.ag.gov.au/myregistration/preregister

A useful UoA-internal Foreign Interference Transparency Scheme information website is provided by Legal & Risk.

 

International Sanctions

Sanctions are a form of economic or diplomatic restriction used by governments to signal and potentially curb objectionable actions of other nation states, entities or people, such as abuse of human rights or organised terrorism. You should make sure that your activity does not involve a sanctioned person or entity. Department of Foreign Affairs and Trade maintains a Consolidated List of persons and entities subject to targeted financial or other sanctions or travel bans. In some circumstances, a permit may be issued to allow an activity to proceed despite the Sanctions.

 

Defence Trade Controls (DTC)

The Defence Trade Controls Act 2012 (DTC Act) controls the tangible and intangible supply of technologies on the Defence and Strategic Goods List (DSGL). The export from Australia of listed goods and technologies is strictly controlled and a permit is required. Export can include the transmission overseas of controlled information such as design plans or software. You must have a permit if you intend to transmit controlled technology to a foreign entity or person or publish information about certain military technologies.


*** Government has decommissioned the online DSGL search tool. You will be asked to search a PDF version of the list instead ***

 
 

*** CLICKING ON LINKS MAY LOSE YOUR DATA ***

Normal clicking on a link will navigate away from the form. To ensure that you do not lose any data you have entered into the form, please ensure that you open any link references in a new tab or window (e.g. by right-clicking or middle-clicking on the link).

 
 

Guidelines:

  1. A "procurement" is the purchasing of a good or service for a fee (e.g. lab equipment, or a piece of software).
  2. A "foreign visitor" is a person that is not a citizen or permanent resident of Australia that is visiting the University of Adelaide: see Note 1 above for instances that are exempt from registration.
  3. UoA has compliance obligations when hiring foreign citizens whther or not a visa is required - there are now "form purpose" option for this.
  4. An "appointment" refers to secondary employment, and/or honorary affiliate or adjunct roles at other academic institutions.
  5. A "practice of a discipline" activity is a consultancy or discipline-specific activity for which you personally receive a financial benefit.
  6. A "philanthropic gift/grant" is an agreement to receive a benefit that does not place any formal obligations on the recipient.
  7. A "workplace based learning" activity refers to student placements arranged by UoA.
  8. All other activity (except student placements which are given their own "purpose") can be considered to be an "engagement", for example any of (not an exhaustive list):
  • Research grant
  • Contract research
  • Memorandum of Understanding (MoU)
  • Material Transfer Arrangement (MTA)
  • Non-personal consultancy (i.e. one where the benefit is retained by the school/faculty)
  • Academic activity in an area of concern and/or one attracting personal benefit exceeding the Conflict of Interest threshold of $500 (co-supervison, thesis reviews, etc.): see Note 2 above.


For cases other than 1-7 above, when making your selection, please indicate if this is a new engagement, a renewal or variation (with or without prior FECR-endorsement).


A renewal or variation option can be chosen if and only if there exists a fully executed formal agreement for the engagement, and that agreement is being renewed or varied. These options cannot be used if the engagement is a resubmission of a previously unsuccessful grant application - in such cases please submit the grant application as a new engagement.


You can view your prior FECR submissions (e.g. to copy some prior content) here (you will need a SmartSheet account with your UoA email address as username - that can be obtained here).


Please contact dso@adelaide.edu.au if you require further clarification.

 
 

RESPONSIBLE STAFF MEMBER, ADJUNCT OR AFFILIATE DETAILS

The automated workflows of this system will not work without a valid UoA staff/adjunct/affiliate (not student) ID entered in this section.


The Responsible Staff Member would normally be an academic member of staff.


If the academic that is responsible for this activity is not currently a UoA staff member, adjunct or affiliate (e.g. you/they do not have a UoA employment/adjunct/afffiliate contract, you/they are a student, or are applying for a grant which if successful will bring you/them to UoA as an employee) then:

  1. This section needs to contain the details of your/their current or intended UoA supervisor. The UoA employee ID of that supervisor MUST be entered - you may ask them to provide you with this information.
  2. You should answer "Yes" to the question (above) "Are you doing this on behalf of another person".
  3. You should enter your own details in the "Submitting Person" section. Please provide BOTH your name and email address in the "Submitting Person's Name" field.


Otherwise, if you are registering your own foreign engagement activity then enter your own details (e.g. if you are the lead researcher).


Otherwise, if submitting on behalf of someone else (e.g. if you are a member of professional staff submitting an activity on behalf of the lead researcher), please enter their details in this section. Select "Yes" above in answer to the "Are you doing this on behalf of another person?", and enter your own details as the "Submitting Person". If in doubt contact dso@adelaide.edu.au.

 

Please enter the 7 numeric digits of the UoA ID (leave out the "a"). This field must contain a valid staff/adjunct/affiliate (not student) ID number, and cannot contain any non-numeric characters.

 

If this person is responsible by reason of being a supervisor of a student or of a non-employee, the suggested format to use here is:

  • "supervisor name", responsible as supervisor of "student or non-employee name"
 
 
Privacy Policy
Report Abuse
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.