The purpose of our policy and procedure
To state our foreign compliance principles and governance responsibilities relating to foreign compliance activities.
Who our policy and procedure applies to
- Adelaide University staff
- Adelaide University students, including prospective students and prospective graduate research students
- Adelaide University titleholders
Our Foreign Compliance Policy principles
Adelaide University supports the Australian Government’s national security agenda by giving foreign compliance obligations priority consideration before proceeding with any foreign engagement. We recognise that non-compliance with foreign engagement laws can have major consequences for individuals, Adelaide University and Australia.
- We will comply with legislation related to national security, foreign arrangement, foreign influence, transparency and foreign interference, including:
- Australia's Foreign Relations (State and Territory Arrangements) Act 2020
- Defence Trade Controls Act 2012 and Defence Trade Controls Amendment Act 2024
- Autonomous Sanctions Act 2011
- Foreign Influence Transparency Scheme (FITS) Act 2018
- Criminal Code Act 1995
- Defence Amendment (Safeguarding Australia’s Military Secrets) Bill 2024.
- Our operations will align with the University Foreign Interference Taskforce Guidelines to Counter Foreign Interference in the Australian University Sector (UFIT Guidelines). (UFIT Guidelines).
- All staff and foreign citizen Graduate Research students are required to declare any interests, including identification of foreign affiliations, relationships, and financial interests in accordance with the UFIT Guidelines.
- Training will be provided to staff and students who are engaged in foreign collaboration or other partnership activities subject to national security and foreign compliance requirements.
- At Adelaide University diligence and compliance with our Foreign Compliance Policy is the responsibility of all staff, students and titleholders.
1. Foreign Compliance Review (FCR)
Adelaide University has developed a Foreign Compliance Review (FCR) process to ensure our compliance with relevant national security legislation.
An FCR is required when we conduct certain activities. The activities listed below, involving our staff, students, or titleholders may only proceed once they have been approved through the Foreign Compliance Review (FCR) process, which is managed by the Office of the Chief Security Officer.
- Recruiting a foreign citizen to any role within Adelaide University
- Individual staff appointments with any foreign entity
- Individual staff ‘practice of a discipline’ engagement with any foreign entity
- Any grant application or agreement that involves a proposed international partner (including grants, contract research, consultancies, collaborations joint ventures, partnerships, alliances, memberships and affiliations)
- Invitations to invite an overseas based individual/entity to visit the University
- Foreign students undertaking an Adelaide University Graduate Research Program or Graduate Research Pathway program
- Procuring goods and/or services from any foreign entity
- Request approval to proceed with a new foreign agreement
- Request approval to renew an existing foreign agreement, previously FECR endorsed.
The FCR process
The Office of the Chief Security Officer can be contacted to query the status of any FCR submission by emailing dso@adelaide.edu.au.
2. Non-compliance
Non-compliance with this Policy may lead to criminal prosecution or disciplinary action.
Definitions used in our policy
A foreign arrangement is a written agreement, contract, understanding or undertaking between Adelaide University and a foreign entity, whether or not there are any other parties to the arrangement or whether it is legally binding or not
Foreign Compliance Review is Adelaide University’s process for ensuring international engagement is in line with Australia’s foreign compliance obligations and Adelaide University’s interests.
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 interests1.
Foreign influence means1 all governments, including Australia’s, try to influence deliberations on issues of importance to them. These activities, when conducted in an open and transparent manner, are a normal aspect of international relations and diplomacy and can contribute positively to public debate.
Graduate Research Program means a program at doctoral or master level which comprises two-thirds or more of its assessable content by research.
Student means a person enrolled in an Enabling Program, award or non-award coursework study, a research program, or a short course or microcredential at Adelaide University.
Prospective Graduate Research Student is a person who has contacted Adelaide University, or an agent representing Adelaide University, with the intent of becoming a graduate research student.
Prospective Student is a person who has contacted Adelaide University, or an agent representing Adelaide University, with the intent of becoming a student.
[Titleholders means any person upon whom Adelaide University has conferred an honorary academic title.]
Please refer to our Adelaide University glossary for a full list of our definitions.
1 ‘Foreign interference’ versus ‘foreign influence’, Guidelines to counter foreign interference in the Australian university sector, November 2021
How our policy and procedure is governed
Our Policy is categorised, approved and owned in line with the governance structure of Adelaide University and the offices and officers listed below.
| Policy category | Corporate |
| Approving authority | co-Vice Chancellors/Vice Chancellor and President |
| Policy owner | Deputy Vice Chancellor - Corporate |
| Responsible officer | Chief Security Officer |
| Effective from | 17 February 2025 |
| Review date | 17 February 2026 |
| Enquiries | Interim Central Policy Unit |
| Replaced documents | None |
Legislation and other documents related to this policy and procedure
Australia's Foreign Relations (State and Territory Arrangements) Act 2020
Defence Trade Controls Act 2012 and Defence Trade Controls Amendment Act 2024
Foreign Influence Transparency Scheme (FITS) Act 2018
Guidelines to counter foreign interference in the Australian university sector
Defence Amendment (Safeguarding Australia’s Military Secrets) Bill 2024
History of changes
| Date approved | To section/clauses | Description of change |
|---|---|---|
| 11 Feb 2025 | N/A | New policy |
Note on structures, positions and position titles:
At the time of writing, the organisational structure, positions and position titles for Adelaide University have not been confirmed. Accordingly, square brackets [ ] temporarily enclose position titles in this policy and procedure until position titles for Adelaide University are known.