RATIONALE

Prudent management of the College’s financial resources is essential to the on-going operation of the College and to facilitate achievement of the best quality education outcomes for its students.  This requires the maintenance of high standards of planning and control.

GUIDELINES

 1          Financial Management

Annual budgets will be prepared for all departments and non-curriculum cost centres and in aggregation for the College.  These will be approved by the Board and be in place by 1 January of each financial year.

Budgets will include:

• an operations budget
• a capital budget, which will contain specific details of capital items to be acquired, and

Actual performance against budget will be measured and reported monthly to Faculty heads, the Principal and the Board. 

2          Authorities

Delegated financial authority shall be given to individuals best able to exercise those authorities.  Employees at all levels will only take decisions within the authority delegated to them.

3          Internal Controls

Adequate controls will be maintained to give assurance that financial processes and procedures are effective and efficient, that financial results are timely and reliable, that financial and property assets are safeguarded and that laws and regulations are complied with.

4                      Sensitive Expenditure                

The Board requires the Principal, where expenditure may be beneficial to an individual or group of individuals, to take account of the following prior to authorising the expenditure:

1. Does the expenditure benefit student outcomes?
2. Does the expenditure represent the best value for money?
3. Is it in the budget?
4. Could the Board justify this expenditure to a taxpayer, parent or other interested party?
5. How would the public react if this expenditure was reported by the media?
6. Would there be perceived to be any personal gain from this expenditure?

5          Investments

The investment of funds is governed by the Education Act.  The Board may place funds on deposit or invest in debt securities with registered banks, subsidiaries of registered banks, and/or in public securities issued by the government.  Investments can only be made outside these areas with approval of the Ministry of Education (Te Mahau).

6          Capital Expenditure

Capital items can only be acquired in line with the approved capital expenditure budget.  Board approval is required for the acquisition of any capital items not detailed in the budget.

7          Credit/Debit Cards

Credit/debit cards are to be issued only with the express approval of the Board and are to be used only for College activities; cards are not to be used for personal expenditure.  Receipts are to be retained in support of all card expenditure.  Cash advances are not permitted.  All expenditure is to be reviewed.  The Principal’s expenses are to be reviewed and signed off by the Board Chair.  Self approval of expenditure by cardholders is not allowed.

8          Conflicts of Interest

Board members and employees are at all times to act in good faith and in the best interests of the College.  Board members are to declare any interests which conflict, might conflict or might be perceived to conflict with the interests of the College.

A conflict of interest may be financial or non-financial, direct or indirect, professional or family related.

In particular any interest by a Board member, or any employee of the College, in any contractual matter involving or potentially involving the College is to be declared and managed.

9      The Principal shall institute Procedures pursuant to this policy.

RATIONALE

1.      Outside agencies or businesses have access to resources and provide opportunities that are not readily available to the College and which can enhance and promote desirable activities.

2.       The purpose of the policy is to provide guidelines for any sponsorship activity.

3        Sponsorship is different from a donation in that a donor to the school receives no benefit from the school – except in some cases a simple public acknowledgement of the donation in, for example, the school newsletter.  Whereas a sponsor receives a more direct and substantial benefit from their sponsorship – for example, the right to refer to the sponsorship in their own marketing and thereby share in the goodwill the school receives from the community.

GUIDELINES

1. Funding applications for assistance with sports trips, cultural trips etc. are not covered under this policy.
2. Before an approach for major sponsorship can be made, a plan must first be developed. It should include rationale, fit with school values and policies, method of promotion, how such sponsorship would be managed, and the College’s role in it.

3. Any sponsorship plan must have senior management approval before it is sought.

4. Any sponsorship entered into must be documented to detail the respective commitments of the school and the sponsors to the plan.

5. The sponsorship agreement must take the form of a Contract and must have a fixed termination date.

6. Sponsorship Agreements cannot be entered into without prior Board approval.

7. Any default or liability clauses must be established prior to the signing of the contract.

8. The securing of sports sponsorship must comply with College Sport Regulations and/or guidelines (e.g. size of logos), and other regulations as appropriate.

9. The management of sponsorship/finance must be done through the College accounting system.

10 Individual sponsorship may only be sought after consultation with the Board.

11. The sponsorship plan will provide for, and the staff member responsible for the sponsorship, will ensure that there is appropriate communication, as well as thanks and feed back to the sponsors.

12        The Principal will institute Procedures pursuant to this policy.

RATIONALE

1. If a student withdraws from their course of study before the completion date, they may be eligible for a refund of fees.
2. The refund conditions must align with our obligations as a member school of SIEBA (Schools International Education Business Association) and the International Student Application Form and Contract of Enrolment.

GUIDELINES

1. In every case, the school undertakes to look fairly at requests for a refund of fees or part-fees.
2. The school will consider all requests received in writing to the Principal for a refund of international student fees. Requests must be made in writing to the school as soon as possible after the circumstances leading to a request.
3. A request for a refund should provide the following information to the school:

1. The name of the student;
2. The circumstances of the request;
3. The amount of refund requested;
4. The name of the person requesting the refund;
5. The name of the person who paid the fees;
6. The bank account details to receive any eligible refund; and
7. Any relevant supporting documentation such as receipts or invoices.

4. Unless otherwise agreed in writing, all refunds will be paid into the nominated bank account, which may be a bank account in the source country. Fees incurred by the school for payments into a foreign bank account will be deducted from the refund.

Non-refundable Fees

5. The school is unable to refund some types of fees. The following fees relate to expenses that the school may have paid or will incur as a result of receiving an application for enrolment and cannot be refunded:

1. Administration Fee: Administration fees meet the cost of processing an international students application. Administration fees exist whether an application is accepted or not or whether a student remains enrolled after an application is accepted;
2. Insurance: Once insurance is purchased, the school is unable to refund insurance premiums paid on behalf of the student. Students and families may apply directly to the insurance company for a refund of premiums paid;
3. Used Homestay Fees: Homestay fees paid for the time the student has already spent in a homestay cannot be refunded. Used homestay fees will include a notice period of two weeks;
4. Portion of Unused Tuition Fees: The school may retain a portion of unused tuition fees. Amounts retained will relate to costs that have been incurred or committed by the school and may vary; and
5. Other Costs Incurred: Any other costs already incurred.

Request for a Refund Prior to Enrolment

6          If the Student fails to obtain an appropriate study visa, a refund of International

Student tuition fees will be refunded in full provided less any  non-refundable Fee that has been paid.

Request for a Refund – voluntary withdrawal prior to enrolment:

7. If the student voluntarily withdraws less than 21 days before to the start date of their enrolment, a refund  of tuition will be provided less a minimum of 10 weeks tuition any relevant non-fundable fees  out in this policy.

Request for a Refund – voluntary withdrawal after enrolment:

8. The ten week notice period will begin the day after the date on which the school receives  written notice of the student’s intention to withdraw.

9. If the student voluntarily withdraws on or after the start date of their enrolment,  reasonable written notice of withdrawal is required.

10. Unless  otherwise agreed by the school,  a refund will be provided less a minimum of ten (10) weeks tuition fee and any other relevant non-fundable fees set out in this policy.

Request for a refund for enrolment of one term or less

11        Where the student is enrolled for one term or less and withdrawals early, or where the school terminates the student’s enrolment, any unused portion of tuition will not be refunded.

Request for a Refund – where the school fails to provide a course, ceases as a signatory, or ceases to be a provider:

12        If the school fails to provide the agreed course of education or is no longer a signatory to The Education (Pastoral Care of Tertiary and International Learners) Code of Practice 2021, or no longer operates as an international education provider, the school will negotiate with the student or their family to either:

1. Refund the unused portion of the international student tuition fee or other fees paid for services not delivered; or
2. Transfer the amount of any eligible refund to another provider; or
3. Make other arrangements agreed to by the student or their family and the school.

Where the Student’s enrolment is ended by the School:

13        In the event the Student’s enrolment is ended by the School for breach of the Contract

of Enrolment, the School will consider a request for a refund less:

1. any non-refundable fees set out in this policy;
2. ten weeks tuition fee from the date of termination; and
3. any other reasonable costs that the school has incurred in ending the student’s enrolment.

If an international fee-paying student changes to a domestic student during the period of enrolment

14        If the student changes to a domestic student after the start date of their enrolment,

reasonable written notice of the change is required by the school. Unless otherwise agreed by the school, a refund will be provided less a minimum of ten weeks tuition fee and any other relevant non-fundable fees set out in this policy. The ten week notice period will begin the day after the date on which the school receives written notice and evidence of the student’s domestic student status. As a domestic student, the student will be required to live within the school’s zone.

If an international fee-paying student requests to transfer to another signatory:

15        If the student requests to transfer to another signatory after the start date of their enrolment, reasonable written notice of the transfer is required by the school. Unless otherwise agreed by the school, a refund will be provided less a minimum of ten weeks tuition fee and any other relevant non-fundable fees set out in this policy. The ten week notice period will begin the day after the date on which the school receives written notice of the student’s intention to withdraw.

Request for a Refund  - of Homestay Fees

16        If for any reason, the student withdraws after the start date of their enrolment, any unused homestay fees will be refunded, less any relevant non-fundable fees set out in this policy.

17       Where a student moves from a school homestay and requests a refund any unused  homestay fees, will be refunded less any relevant non-fundable fees set out in this policy.

Request for a Refund - of Fees Unused at the end of Enrolment

18. Except by written request from parents, prepaid fees unused at the end of enrolment  amounting to less than NZD$100 will be refunded to the students nominated bank account. Sums of NZD$100 or greater will be refunded into a bank account nominated by the student’s parents.

Outstanding Activity or Other Fees

19. Any activity or other fees incurred by the student during enrolment and owed to the school at the time of withdrawal, will be deducted from any eligible refund.

Compassionate Refunds

20. In exceptional circumstances, refunds may be granted on compassionate grounds (e.g.  death of a close family member, serious illness, accident). 

21. All such refunds will be at the discretion of the Principal.

Rights of families after a decision regarding a refund has been made

22. A decision by the school relating to a request for a refund of international student fees will be provided to the student or their parent or legal guardian in writing and will set out the following information:

1. Factors considered when making the refund decision;
2. The total amount to be refunded; and
3. Details of non-refundable fees.

23. The student and the their parent or legal guardian has the right to take a grievance to  the Code Administrator or Disputes Resolution Scheme in the event they are dissatisfied with a refund decision made by the school.

General

24. The New Zealand Immigration Service will be notified if any student ceases to attend Newlands College for whatever reason.

25. The Principal shall institute Procedure pursuant to this Policy.

26. This policy will be reviewed as part of the annual self-review.

Rationale:

International Student Fees must be processed in a manner that is consistent with normal accounting practice. Funds need to be secure from misappropriation, and be available to the student in accordance with the Refund Policy and in accordance with The Educational (Pastoral Care of Tertiary and International Learners) Code of Practice 2021 should the school not be able to continue to provide tuition. Funds should only be made available to the school once the income associated with those funds has been earned.

Purpose

1. To ensure that funds from international students are accounted for in such a way that individual student contributions can be monitored and protected.
2. To ensure in the event that the school is unable to continue to run a course or programme the unspent portion of the fees is available to be returned to the student.
3. To ensure that refunds of fees can be made to the student in accordance with the Refund Policy.
4. To ensure that funds are released to the school in a timely manner once the revenue associated with those funds has been earned.

Guidelines

1. Funds from international student fees will be separately coded and accounted for.
2. There will always be access to funds to refund unspent international fees throughout the year.
3. Accounting and administration procedures are in place to record and identify funds held on behalf of each individual student.
4. Funds shall be released to the school for course costs not more often than monthly, in arrears. Where funds are held by the school on behalf of other parties (e.g. homestay payments) then funds shall be released for payment as required.
5. Accounting records and bank accounts will be audited on an annual basis.
6. Details of this Fee Protection Policy will be provided to parents in written form upon enrolment.
7. The Principal shall institute Procedures pursuant to this policy.

Rationale

1.  To ensure the safety and well-being of the students studying at Newlands College.
2. To ensure that the school is protected in the event of an emergency.
3. To ensure compliance with The Education (Pastoral Care of Tertiary and International Learners) Code of Practice 2021.

 Policy Requirement Advice

1.  All students are required to have appropriate and current medical, travel and personal effects insurance for the duration of their planned study, as specified in the Code.
2. The education provider shall advise all prospective students of the standard wording as set out in the Code of Practice, and provide information on the education provider’s medical and travel insurance requirements.
3. Students purchasing insurance must purchase insurance cover at the time of fee payment and before they leave their home country.
4. Where insurance is provided from a New Zealand company, policy details should be provided in the student’s first language where possible.
5. In the case of overseas policy providers, students must provide the school with the policy details in English, before the student attends classes.

Verification of Policies

• Verification of policies will be undertaken prior to enrolment in accordance with The Education (Pastoral Care of Tertiary and International Learners) Code of Practice 2021.

As part of the verification process Newlands College shall ensure that:

1. The insurer/re-insurer is a reputable and established company with substantial experience in the Travel Insurance business, and has a credit rating no lower than A from Standard and Poors, or B+ from A M Best.
2. The Insurer is able to provide emergency 24-hour, 7 day per week cover.
3. Students have a “certificate of currency” and policy wording from the Insurance company stating that the student has purchased the cover for the duration of the planned period of study. The certificate and policy wording must also detail medical sums insured, repatriation benefits etc.

Where a student is not in possession of an appropriate and current medical and travel insurance policy the school undertakes to:

1. Advise the student of the medical and travel insurance requirement.
2. Provide the student with a default policy or policy choices which meet the requirements of the Code of Practice Guidelines.

The cost of default insurance will be met by the student.

Recording of Policy Details

For each student Newlands College shall record the:

1. Name of the insurer
2. Policy number
3. Policy start and end dates

Policy Renewals

For each student, prior to the expiry of their medical and travel insurance policy Newlands College shall issue a written reminder to the student advising that policy renewal must be completed.

Rationale

 Newlands College undertakes to comply with the accommodation provisions set out in The Education (Pastoral Care of Tertiary and International Learners) Code of Practice 2021. The categories of accommodation that will be accepted by the school are:

1. Living with their natural parent or legal guardian
2. Living with a designated caregiver
3. Living in a homestay arranged by the school

Policy Objectives

1. To provide a suitable living environment conducive to study and a safe and supportive home life.
2. To involve the residential caregivers in the welfare of a student away from the student’s family and home country.
3. To assist the student to successfully integrate into New Zealand life.
4. To ensure the student is well cared for and supported by the school.

Provision of Accommodation

Newlands College will arrange homestay accommodation for international students who are not staying with a designated caregiver or parent.

Use of Accommodation Agents

Newlands College will not make use of accommodation agents to organise and monitor student accommodation.

Administrative Requirements and Understandings

General

1. No student, regardless of age, will be permitted to rent a flat/room/house/apartment or live on their own.
2. All accommodation queries and pastoral care issues or concerns arising from accommodation arrangements will be referred to the Homestay Coordinators.
3. For each student, the full name, current address, contact phone number, occupation and relationship to student of the residential caregiver will be held.
4. Any serious concerns relating to accommodation will be reported to the Code Administrator for The Education (Pastoral Care of Tertiary and International Learners) Code of Practice 2021.

  Students Not Living with a Parent

 For all students not living with a parent:

1. Any accommodation to be used by international students will have:

• An on-site assessment to determine that living conditions are of an acceptable
• An assessment to determine that the accommodation type is not a boarding
• An assessment of the residential carer’s suitability and whether they will provide a safe physical and emotional environment. 

2. Each student will be interviewed at least quarterly to ensure that their accommodation is suitable.

3. All accommodation residences will be visited twice yearly to ensure they remain suitable.

4. Safety checks, including Police vetting will be carried out on all adults aged 18 years and over living in a homestay, or designated caregiver accommodation used by a student.

5. Newlands College will conduct follow up visits if there are reasonable grounds to suspect that the accommodation has become unsuitable.

Homestay

6.  The School will have written Residential Caregivers Agreements with all homestays.

7. The School will have written Homestay Accommodation Agreements with all students and their families.

 8. Students in the school homestay programme must make homestay payments in advance

of the commencement of their programme. These are held by the school on behalf of the students and paid to host families in regular payments. Remaining homestay fees at the end of enrolment will be refunded according to the school’s refund policy.

9. Students staying in a homestay are required to exhibit appropriate behaviour. Where a student’s behaviour or demands are such that homestay hosts cannot reasonably be expected to have the student continue in their care, they must notify the provider immediately. The homestay service may be discontinued and the student may be sent home.

10. Where the homestay student wishes to withdraw from the programme, at least two weeks notice must be given in writing to the International Student Director. These may be refunded according to the schools refund policy.

11. Advice and a support infrastructure for homestay carers will be provided by the Homestay Coordinator.

Designated Caregivers

12. The school will have written Designated Caregiver Agreements with all Designated

            Caregivers.

13. The Monitoring of students living in designated care will be managed in accordance with this policy and the Designated Caregiver Agreement.

            Temporary Accommodation:

• The school will assess the suitability of the accommodation considering the age and gender of the students.
• The school will ensure adequate supervision is in place for all students.
• The school will ensure all pastoral needs of the students are met including meal and laundry.
• The school will ensure that supervisors undergo an appropriate safety check.
• The school will monitor and manage risks to students.

Divisions of Responsibility

Newlands College will be responsible for:

• Providing a 24/7 emergency contact person for problems with accommodation.
• Selecting, monitoring and approving all accommodation.
• Providing a support infrastructure for homestay carers.
• Recording the results of all accommodation assessments.
• Recording the results of all quarterly student interviews.

Caregivers

Newlands College will expect all Homestay and Designated Caregivers to provide a safe and friendly, living and studying environment as detailed in the Homestay booklet provided by the college.

The Principal shall institute procedures to effect this policy.

Renew: The School shall review this policy as part of the annual self-review.

PURPOSE:

This policy is to provide clear and consistent guidance for relationships between the school and education agencies. This policy should be read in conjunction with the Agency Agreement, and The Education (Pastoral Care of Tertiary and International Learners) Code of Practice 2021

 CONTRACTS

The school will sign agreements with all education agencies who recruit students for the school.

REFERENCE CHECKS

The school will enter into working relationships with reputable agencies, once two reference check have been carried out and all supporting documentation has been submitted by the agency, i.e. an Agency Application Form, and other supporting documentation the school deems necessary. Results of reference checks will be recorded by international staff. 

ETHICAL CONDUCT

New Zealand is a signatory to the Statement of Principles for the Ethical Recruitment of International Students by Education Agents and Consultants (To be known as the London Statement of Principles) and operates under The Education (Pastoral Care of Tertiary and International Learners) Code of Practice 2021. Recruitment agencies will be informed about, and will comply with the requirements of the Code and the London Statement of Principles.

ACTION FOR BREACH

Where agencies are found to contravene the Code and/or the London Statement of Principles, the school will apply the appropriate sanctions as detailed in the Agency Agreement.

COMMISSIONS

The school will pay commission to the agency as set out in the Agency Agreement. The commission rate will generally be 15% of annual tuition fees and the school reserves the right to make other commission or incentive arrangements with selected agencies by special negotiation.

The school will generally pay commissions to contracted agencies upon receipt of an invoice. Commission payments will be made within 4 weeks after the student has commenced at the school and is subject to the tuition fee being received by the school.

The school may elect to make special arrangements with trusted agencies to allow the agency to withhold commissions from tuition payments due to the school. Such arrangements are at the sole discretion of the school and no commissions should be withheld by an agency without prior agreement from the school.

Managing Recruitment Agencies:

A formal approach to the Code Administrator where a student is unable to access a school’s internal grievance process or is dissatisfied with the outcome of that process.

Where a student does not see out the entire period of their enrolment at the school, the school may, on a case by case basis, decide whether or not to request a refund of all or any part of any commission fees paid to an agency.

The school will have no obligation to pay commission fees to any agency with whom the school does not have a signed Agency Agreement.

AGENCY MONITORING AND REVIEW:

The school will review the conduct and performance of its agencies as a part of an annual self-review. The school will collect and record appropriate evidence of agency reviews.

REPORTING:

The staff member in charge of international education will report directly to the school Principal on the performance of the school’s contracted agencies and report any breaches of the Code that may lead to the termination of an agency contract. 

 The Principal shall institute procedures to effect this policy.

Renew: The School shall review this policy as part of the annual self-review.

PURPOSE:

This policy outlines factors that will be considered when managing supervised groups enrolling at the school. This policy should be read in conjunction with The Education (Pastoral Care of Tertiary and International Learners) Code of Practice 2021 and the Education and Training Act 2020.

RATIONALE:

Newlands College has developed a Supervised-Groups Policy:

• To ensure that students enrolling at the school as part of a group are properly supervised
• To ensure the safety and well-being of the students and the quality of academic and social education of all International Students studying at the school.
• To ensure compliance with The Education (Pastoral Care of Tertiary and International Learners) Code of Practice 2021. 

A supervised group is considered to be:

• Two or more international students travelling together in New Zealand under the supervision of a person or organization other than Newlands College, and enrolling at Newlands College as international students for periods up to three months. 

POLICY OBJECTIVES: 

1. To promote international understanding and enhance globe citizenship at Newlands College
2. To ensure the safety and wellbeing of all supervised-group students that enrol at Newlands College
3. To consider the particular needs of students enrolling as part of supervised groups and ensure the administration and pastoral care provided for supervised-group students meet the requirements of the Code.

 ENROLMENT OF SUPERVISED GROUP STUDENTS

 Newlands College will enrol supervised-group students on the ENROL system as per Ministry of Education Guidelines for groups to ensure that these students are recorded as international students.

 USE OF EDUCATION AGENTS

The International Student Director will ensure that we do not accept any supervised-group students through an education agent without first following our policy and procedures for the management of education agents, including having a signed and current Agency Agreement with the education agent.

In order to ensure that Newlands College and an education agent understand and meet their duty-of-care for the students, the International Student Director will draft, and ensure that both parties sign a memorandum of understanding for each supervised-group. The memorandum of understanding will provide details of the group including, expected number, ages and genders of students, arrangements for group supervision and accommodation, agreed pricing schedules, important timelines, program requirements and the roles and responsibilities of both parties.

ACCOMMODATION FOR SUPERVISED-GROUP STUDENTS

Newlands College will ensure that supervised-group students stay in appropriate accommodation as defined in the Code.

Appropriate accommodation may be:

• Residential caregiver. This includes school homestays and the school hostel
• Hotel, motel, unlicensed hostels or other supervised-group accommodation options
• Staying with students’ parents or legal guardians

INSURANCE FOR SUPERVISED GROUP STUDENTS

IMPORTANT NOTE:

The Code requires that all students enrolled with a signatory for 2 weeks duration or longer must have appropriate insurance cover. In order to better fulfil our duty-of-care for all international students enrolled at Newlands College, this policy requires all international students to have appropriate insurance cover including those who enrol at the school for less than two weeks.

Newlands College will therefore ensure that all supervised-group students have appropriate insurance for the duration of their enrolment, and if practicable, for the duration of their time in New Zealand including travel between their home country and New Zealand. Insurance policies, whether arranged by the school or the student or their family, will be deemed to be appropriate if they provide cover for:

• medical expenses to the value of NZ$1,000 000 to unlimited
• repatriation or expatriation of the student as a result of serious illness or injury, including cover of travel costs incurred by family members assisting repatriation or expatriation; and
• death of the student, including cover of:
  • travel costs of family members to and from New Zealand; and
  • costs of repatriation or expatriation of the body; and
  • funeral expenses

GROUP SUPERVISION

Newlands College will ensure that groups enrolling at the school have proper supervision. The number of supervisors and the type of supervision for a group will be negotiated and detailed in the memorandum of understanding. Factors in deciding proper supervision will include:

• The number of students
• The ages and genders of the students
• The duration of the visit
• The levels of students’ English language proficiency
• The activities that the students will be involved in

If Education Outside the Classroom (EOTC) activities are undertaken, the school’s EOTC guidelines will determine appropriate supervision ratios and other safety measures put in place for these activities.

ORIENTATION

Supervised-group students will be provided with an orientation on arrival as per the school orientation procedures.

VISAS

The school will ensure that all students enrolling as part of a supervised group will have the appropriate visa to study at Newlands College

 The Principal shall institute procedures to effect this policy.

Renew: The School shall review this policy as part of the annual self-review.

RATIONALE:

1. The Board has a responsibility to protect the physical and financial resources of the School.
2. The responsibility for preventing and detecting theft and fraudulent actions by persons who are employed or contracted by the School or who are service recipients of the School, rests with the Management Team through the implementation and continued operation of adequate internal control systems.
3. The Board accepts that any investigation into any theft or fraudulent actions must be conducted in a manner that conforms to the principles of natural justice and is procedurally just and fair.
4. The high standards of behaviour expected of individuals entrusted with public money mean that, when fraud is committed, the same high standards must be applied to ensure that the perpetrators are brought to justice, and that there is an accompanying level of accountability and disclosure.

GUIDELINES:

Measures to Prevent Theft and Fraud

1. The Board requires the Principal to take reasonable and prudent measures to ensure that:

1. The School’s physical resources are kept secure and accounted for.
2. The School’s financial systems and processes are designed to prevent and detect the occurrence of fraud.
3. Staff members who are formally delegated responsibility for the custody of physical and financial resources by the Principal are:
   1. competent to carry out such responsibilities;
   2. aware of the parameters of their responsibilities; and
   3. held accountable for the proper execution of their responsibilities.
4. All staff members are aware of their responsibility to immediately inform the Principal should they suspect or become aware of any improper or fraudulent actions by staff, suppliers, contractors, students or other persons associated with the School.

Procedures Regarding an Allegation of Theft and Fraud

• In the event of an allegation of theft or fraud, the Principal shall carry out one or more of the following procedures as appropriate:
  
  

• Initiate and investigate into the matter;
  
  
• If a prima facie case is thought to exist to continue with their investigation;
  
  
• Seek legal advice;
• Notify school insurer;
  
  
• Lay a complaint with the New Zealand Police;
  
  
• If necessary, commission an independent expert investigation;
  
  
• Inform the Manager, National Operations, Ministry of Education (Te Mahau).local office and the school’s auditors.

2. Once all available evidence is obtained, the Principal shall consult the Board The Board Chair may, if they consider it necessary, seek legal or other advice as to what further action should be taken.

3. If a case is considered to exist, the Principal or a person designated by them shall, (unless another course of action is more appropriate):

1. Inform the person(s) in writing of the allegation that has been received and request a meeting with them at which their representative or representatives are invited to be present.
   
   
2. Meet with the person(s) who is(are) the subject of the allegation of theft or fraud and their representatives to explain the complaint against them.
   
   
3. Obtain a verbal or preferably a written response (all verbal responses must be recorded as minutes of that meeting, and the accuracy of those minutes should be attested by all persons present).
   
   
4. Advise the person in writing of the processes to be involved from this point on.

Allegations Concerning the Principal or a Trustee

4. Any allegation concerning the Principal should be made to the Board Chair. The Chairperson will then investigate in accordance with the requirements of Guideline 2 of this Policy and may co-opt or contract such assistance as is necessary to do so.

5. Any allegation concerning a member of the Board should be made to the Board Chair unless it is against the Board Chair, in which case, it should be made to the Deputy Chair. The Chairp, or if against the Chair then the Deputy Chairper, will then investigate in accordance with the requirements of Guideline 2 of this Policy and may co-opt or contract such assistance as is necessary to do so.

General

6. The Board is to be made aware if there is a prima facie case of theft or fraud.

7. The Board recognises that supposed or actual instances of theft or fraud can affect the rights and reputation of the person or persons implicated. All matters related to the case shall remain strictly confidential with all written information kept secure. If any staff member or Trustee breaches confidence with such information, the Principal and /or Board Chair shall consider what action is required, having regard to the conditions of employment (for staff) and appointment (for Board members).

8. The Board affirms that any allegation of theft or fraud must be subject to due process, equity and fairness. Should a case be deemed to be answerable then the due process of the law shall apply to the person or persons implicated.

9. The recovery of the lost money or other property will be pursued wherever possible and practicable.

10. The Principal and Board Chair may authorise a statement to inform the school community if a theft or fraud has occurred.

11. The Principal shall institute procedures pursuant to this policy.

RATIONALE

 1. The Board agrees that it has a responsibility to ensure that travel expenditure incurred by the college must clearly be linked to the business of the college.

2. This policy must be read in conjunction with other Board Policies (g. EOTC), and the exercising of all authority and responsibilities conferred under this policy must be in accordance with the Schedule of Delegations and may not exceed an individual’s established level of delegated authority.

3        Planned travel which is a cost to the college should be part of the College’s budget.   Unforeseen travel costs are to be approved by the Principal, or by the Board for travel by the Principal.

PRINCIPLES

 The Board agrees to ensure that:

1. Travel expenditure is on the Board’s business, and the college obtains an acceptable benefit from the travel when considered against the cost;
   
   
2. Expenses are reimbursed on an actual and reasonable basis; and
   
   
3. Staff that are required to travel on business do not suffer any negative financial effect (providing they have followed the guidelines listed below).

GUIDELINES

 1. Under no circumstances may any staff member approve their own travel.

2        As much as possible all bookings for international and domestic travel are to be conducted through the college’s normal purchase procedures.  This includes the booking of accommodation, flights, trains and rental cars etc.
3        Travel bookings are not to be made using personal funds.

4        Any departure from the normal purchase procedures must be authorised by the Principal, prior to the expenditure being incurred. Or,  in the case of the Principal’s travel – the Board.

5        Staff must travel by the most direct route unless scheduling dictates otherwise.

 TRAVEL WITHIN NEW ZEALAND

6          The justification for travel within New Zealand must be documented.  It is to be transparent and must relate to a school need.

7          Travel within New Zealand is to be authorised on a one-up basis.
8          All domestic air travel is to be economy class.

INTERNATIONAL TRAVEL
9        Prior to international travel being undertaken, the traveller must be advised of this policy.
10      A proposal must be put to the Board detailing the purpose of the trip, the expected benefit to the Board which will arise from the trip and an estimate of the costs of the trip. 

11      Approval for travel is at the discretion of the Board.  Approval may be minuted/or by confirming the annual budget.

12      All international travel up to 4 hours of uninterrupted flight duration shall be economy class.
13      Business class, or where available, premium economy class, travel for longer journeys is appropriate where the staff member is expected to work within 24 hours of arrival.

 ACCOMMODATION

14        Staff should opt for accommodation that is appropriate to the purpose of the travel. 

15        Staff who stay privately will be reimbursed on production of receipts, for koha or for

the cost of a gift given to the people they have stayed with.  Prior to travel the staff member should receive authorisation for the value of the intended koha/gift.

 VEHICLES

16        When using rental cars, staff should opt for good but not superior model vehicles and should be prepared to justify any exceptions to this rule to the Principal.

17        Use of private vehicles is to be approved on a one-up basis and reimbursement will be at the rate specified by the various staff employment collective contract motor vehicle allowance rates.

18        If unplanned taxis are used, then staff should pay for the taxis out of their own pocket, obtain a receipt and seek reimbursement through petty cash or as part of an expense claim.  Otherwise petty cash may be used, and a receipt will be provided.

 REIMBURSEMENT OF EXPENSES

 19       The reimbursement of expenses related to business travel will be on the basis of what is actual and reasonable.  Such expenses should be consistent with the line of work for the college that is being undertaken by the claimant.

20       If extra-ordinary expenses are envisaged (e.g. hosting a meal for parents of our International students while overseas) these should be budgeted for and approved by the Principal.

21       The college will not meet expenses incurred on behalf of a spouse or travelling companion.  In the event of a person travelling with an employee, a reconciliation of expenses should clearly demonstrate that the college did in no way incur additional expenditure.

22       All receipts must be retained and attached to the travel claim.  The claim is to be

authorised on a one-up basis, subject to the guidelines contained in the appendix, with regard to authorised amounts.

23       For expenditure incurred in New Zealand of value greater than $50 (including GST)

there should also be a GST invoice to ensure that GST can be reclaimed by the college.

24       Authorisation can still be given for expenditure less than $50 where there is no receipt, for example if it is not practical to obtain a receipt or if the receipt is lost.  The expenditure can be reimbursed provided there is no doubt about its nature or the reasons for it.

25       The Principal shall institute Procedures pursuant to this policy.

RATIONALE

1       Developing and maintaining the buildings, grounds,  facilities and capital registered items and assets of  Newlands College in good order provides a supportive learning environment for students and a high quality working environment for staff.

2       The Board is responsible for achieving this within compliance with the Te Mahau (Ministry of Education) property occupancy agreement, local body regulations, and with appropriate legislation subject to budgetary constraints.

GUIDELINES

1          The Principal shall ensure that all school facilities are in a clean, tidy, safe and hygienic condition.

2          The Board shall:

            2.1       respond to its assessment of the present needs of the community.

            2.2 consider the demographic and community residential changes in order to prepare for future developments
            2.3       oversee the College’s property within budgetary constraints.

             2.4       respond to property needs arising from changes in curricula and assessment.

 3          Each year the Board shall review its property plans as funded by the Te Mahau (Ministry of Education).

4          The Principal shall have overall responsibility for carrying out the Board's property policy decisions.

5          College Facilities may be made available to outside users at the discretion of the Principal.  This would normally be on a hire basis, according to fees set by the management of the College.

6          Costs arising from vandalism shall be recorded separately.  Reimbursement shall be sought from the Te Mahau (Ministry of Education) of any expenses above the annual vandalism grant.

7          The College will seek reimbursement from the perpetrators of vandalism, where practical.

8          The Principal shall institute procedures pursuant to this policy.

RATIONALE

Gifts are defined as a reward, gratuity, or other consideration beyond remuneration and reimbursement. At Newlands College, we understand that giving gifts is subject to a high level of public scrutiny. Compliance with this policy helps the school demonstrate responsible use of public funds and resources, and avoid criticism.

In the context of this policy, koha is considered a type of gift and may be defined as an unconditional or voluntary offering, donation, or token of gratitude. When making decisions about koha, we consider Māori kawa and tikanga (protocols/customs and rules), as well as other cultural considerations. We seek independent advice where necessary to ensure that the giving and receiving of koha aligns with kawa and tikanga, and complies with financial requirements.

All gifts and koha must conform with Inland Revenue regulations. No gifts or koha should be made when the actual circumstances surrounding the payment mean that this would be considered income for the payee and would therefore be liable for tax.

GUIDELINES

1. Giving Gifts (Including Koha)

Newlands College may give gifts to a community group, organisation, or individual to reflect their partnership with the school. Newlands College ensures that gift expenditure is clearly linked to the business of the school, and that gifts do not provide unreasonable personal benefit to any individual or group of individuals. The Principal is delegated by the Board to implement and monitor the process of giving gifts.

We comply with the following requirements for giving gifts:

• Gifts are purchased through the standard purchase procedures and are subject to budget constraints.
• Gifts for a group or individual do not exceed the budgeted amount.
• If a gift is to be given during travel, the staff member receives authorization for the value of the intended gift before travelling.
• The value of gifts for staff is based on length of service, and may also reflect significant achievements.

• Any gifts given should be appropriate to the occasion or reason for being given:

• The cost of a gift should be reasonable.
• The gift should not be able to be publicly perceived as inappropriate, or as a reward or inducement.

2. Receiving Gifts (Including Koha)

Gifts should not be accepted if there is any conflict of interest or concern that acceptance could be seen by others as an inducement or a reward. This would include circumstances where accepting a gift would place the recipient in a compromising position or could be seen as influencing them (directly or indirectly) in decision-making on behalf of the school.

3. Financial Conflicts of Interest

If Newlands College has any doubt about the appropriateness of a gift, we seek independent advice (e.g. NZSTA or Ministry School Finance Advisor).

We comply with the following requirements for receiving gifts:

• If gifts received are small and of low value (under $300), then the recipient may keep the gift. This excludes cash (or cash received as koha).
• If the gift is larger and more valuable, then the recipient must notify Newlands College (via the principal) of the gift. The gift will be given to the school to use unless the Board agrees to an exception.
• If the gift arises from an employee's role as an employee of the school (e.g. a gift or prize offered to a staff member attending an event as a representative of the school), the gift remains the property of the Board. The gift should be declared to the Principal.

4. Cash Gifts

• We encourage our school community to avoid cash gifts where possible. There may, however, be circumstances where it is culturally or otherwise appropriate to accept cash gifts (including as koha). When any cash (including cash as koha) is received, we manage this according to school processes for cash management.
• Any cash received must be promptly banked into the school bank account.
• If a large cash gift or koha is received, the recipient consults with the Board and/or Principal about how to approach this, including considering if the cash or koha should be returned.

5. Gifts to the Board

Newlands College may accept or decline gifts of money or property. If Newlands College intends to retain a gifted security, the Ministers of Education and Finance must provide approval within a year of the school receiving it to meet requirements of the Education and Training Act 2020 and the Crown Entities Act 2004.

Newlands College may also receive gifts or bequests that are conditional on continuing to hold a security in its current form. In this circumstance and on acceptance, a trust is created, and the restrictions referred to in the Crown Entities Act above, on holding securities, do not apply. The Board can continue to hold the security in perpetuity and does not need to seek approval from the Minister of Education.

6. Gift Register

• The school maintains a register of gifts and koha that are given and received by the school.
• The gift register includes a description of the gift, costs, and recipients. All gifts and koha received, including cash received as koha, are recorded in the register. This includes gifts that were offered but declined by the school. The Board reviews the gift register on a regular basis.
• Gifts in excess of $300 and gifts that are attractive in nature (including jewellery, watches, and electronic items) must be recorded in the gift register

7. The Principal shall institute Procedures to effect this Policy.